Laguna Beach City Council
May 13, 2026

Conclusion Summary – HRG Report (Feb 2025)
Criteria for Significance
HRG concludes that the property is historically significant under California Register Criterion 1 (equivalent to National Register Criterion A) for its association with early homesteading in South Laguna. Specifically, HRG ties the significance of the property to the Homestead Act of 1862 and the broader historic theme of agricultural and rural development in the South Laguna area during the early 20th century.

Historic Context
• The property is associated with William F. Egan, a homesteader who claimed the 40-acre parcel in 1910 under the Homestead Act.
• The context for significance is the early Euro-American settlement and agricultural development of South Laguna.
• HRG notes that this is one of the few known homesteads in Laguna Beach and possibly the last remaining property physically associated with homesteading in the area.

Level of Significance
• HRG identifies the level of significance as local, aligning the property’s importance with the history of the South Laguna area and its development prior to annexation by the City of Laguna Beach in 1987.

Period of Significance
• The period of significance is ca. 1909–1928, reflecting the timeframe when William Egan:
o First built the homestead cabin (c. 1909),
o Filed for the homestead claim (1910),
o Expanded the house as his family grew and his agricultural efforts matured (through 1928).

Property Type and Historic Association
• The property is a residential homestead cabin that evolved into a small cottage by 1928.
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• HRG notes that Egan farmed string beans and melons, which were shipped to Los Angeles and San Francisco markets, indicating a commercial agricultural association.
• The structure is described as one of the last physical representations of this pattern of settlement and land use in South Laguna.

Evaluation of Integrity
HRG evaluates the seven aspects of integrity as defined by the National Register and California Register standards and concludes the following:

HRG concludes that the property at 31526 Valido Road retains sufficient integrity to convey its historical significance. They find that the aspects of location, design, materials, workmanship, feeling, and association are all retained, noting that the residence remains on its original parcel and maintains its essential form and fabric from the period of significance. While they acknowledge that integrity of setting has been lost due to the transformation of the surrounding area from rural farmland to suburban development, they argue that the remaining aspects are collectively adequate for the property to convey its association with early homesteading in South Laguna.

Despite the loss of integrity of setting, HRG argues that the property retains sufficient integrity overall to convey its historical significance, particularly as the last known remaining physical vestige of early homesteading in Laguna Beach.

Conclusion Summary – Chronicle Report (April 2025)
Criteria for Significance
Chronicle evaluates the property using the standard federal and state criteria:
• National Register Criteria (A–D)
• California Register Criteria (1–4)
They do not evaluate the property under local Laguna Beach Historic Register criteria, noting that:
• The property is not listed locally,
• The current City ordinance requires owner consent for local listing, • The property owner does not wish to be listed,
• And therefore, local criteria were not considered relevant for CEQA analysis. 452
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Historic Context & Property Type
• Chronicle acknowledges the property was built ca. 1909–1928 and associated with William F. Egan, who filed a homestead claim in 1910.
• However, they reject the notion that this association confers significance under Criterion A.
• They view the property as one of many early 20th-century rural residences, not a rare or distinctive representative of homesteading in Orange County. • Chronicle does not assign a level or period of significance (local, state, or national) because they find the property not eligible under any applicable criteria. • Chronicle acknowledges that some aspects of integrity remain but argues that integrity of setting is critically compromised—and that this is essential to the property’s ability to convey historical significance under Criterion A/1.

Key Rebuttals to HRG’s Findings
Chronicle challenges HRG's conclusions primarily under Criterion A/1. Their main rebuttals are:

1. Loss of Setting Undermines Association with Homesteading o HRG acknowledges loss of setting, but Chronicle argues this loss is fatal to significance under Criterion A.
o They state the property “does not adequately reflect or convey an association with the Homestead Act.”

2. Homesteading Was Not Rare in Orange County
o Chronicle argues that Egan’s homesteading activity was not unique or rare in the County, which saw many homestead claims during the same era. o They note that this event does not stand out as a significant pattern of development in South Laguna specifically.

3. Insufficient Contribution to Broader Patterns of History o Chronicle argues that while Egan may have farmed beans and melons, there is no evidence that his activity significantly contributed to the development of South Laguna or Laguna Beach.

4. Lack of Evidence for Continued or Impactful Agricultural Use o Chronicle presents evidence that Egan relocated by 1920 and there is no record of sustained agricultural production or regional influence afterward. 453
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5. Questioning HRG’s Use of Integrity Thresholds
o Chronicle disputes HRG’s interpretation that six of seven integrity aspects being retained is sufficient.
o They argue that setting is essential in this context and that its loss severs the historical connection to homesteading.

6. Misalignment with CEQA’s Definition of a Historical Resource o Chronicle emphasizes that no listing in a federal, state, or local register, combined with the integrity and contextual issues, supports a finding that the property is not a historical resource under CEQA.

Chronicle argues that:
• The association with homesteading is weak and no longer visible due to loss of setting.
• Egan’s activities were not historically significant in the local or broader context. • The property does not retain sufficient integrity to convey historical significance. • Therefore, 31526 Valido Road is not eligible for the National Register, California Register, or local designation.

Criterion Evaluation Summary
Chronicle Heritage concludes that the property at 31526 Valido Road is not eligible for listing in the California Register of Historical Resources or the National Register of Historic Places under Criterion A / 1 for association with significant historical events. Their central argument is that while the property may have a historical association with early 20thcentury homesteading, it does not retain sufficient integrity of setting to convey that association, nor does it represent a rare or exceptional example of this broader historical trend. Chronicle further argues that homesteading was common throughout Orange County during the period in question, and that the Egan property does not stand out as a unique or illustrative example of this development pattern. In their view, the mere association with homesteading, particularly when the surrounding agricultural landscape has been substantially altered by modern development, is not enough to establish eligibility under Criterion A.

Based on our assessment of both reports we offer the following:

GPA Peer Review:

As part of our professional peer review process, GPA Consulting conducts a thorough and objective analysis to determine whether a submitted historic resource assessment meet accepted professional and technical standards. This is our methodology and scope for the peer review:
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1. We begin by confirming that the report was prepared by individuals who meet the Secretary of the Interior’s Professional Qualification Standards as defined in 36 CFR Part 61.

GPA has reviewed the resumes of the HRG and Chronicle preparer’s and based on the information provided, all professionals appear to meet the Secretary of the Interior’s Professional Qualifications Standards for Architectural History and/or History.

2. We then evaluate whether the report follows the industry’s best practices by including the standard components of a professional historic resource evaluation— such as an executive summary, a clear explanation of the evaluation methodology, and the appropriate application of federal, state, and local significance criteria (e.g., National Register of Historic Places, California Register of Historical Resources, and local landmark designation criteria, as applicable).

The HRG report follows the industry’s best practices and includes components of a professional historic resource evaluation. It is well organized, and includes the sections and information typically found in such an evaluation report. The Chronicle Report also includes the common sections of a historic resources assessment but also offers additional information in the form of a review and rebuttal of HRG’s conclusions. Both reports included sufficient information to understand the property, its history, and their independent conclusions.

3. We assess whether the report properly identifies relevant historic contexts and property types, and whether it draws on appropriate primary and secondary sources housed in recognized public repositories. In doing so, we determine whether any relevant research materials may have been overlooked or if there are gaps in the research methodology.

HRG’s report was well prepared; they provided a thorough history of the property that was supported by sound primary and secondary sources, and they disclosed their sources properly with citations and a bibliography. HRG identified relevant historic contexts under which the property could be potentially historically significant. GPA did not identify any gaps in their research methodology.

The Chronicle Report included a very brief history of the property and its surroundings, a brief building permit and alteration history, a few maps and illustrations in their report. Chronicle conducted an independent evaluation for historic significance, which they stated to have been based on County archive records, County plat maps, building permits, local publications of the history of Laguna Beach and south Laguna area, historic land patents, property assessment 455
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records, historical newspaper articles, County plat maps, and historical aerial photographs. Based on the limited historic context that was provided in the Chronicle report, it appears that their evaluation largely relied on a peer review of HRG’s report and an assessment of integrity for the property. Chronicle cited generic reference materials and guidance bulletins at the end of their report, but only cited limited primary sources, including one newspaper article, two building permits. One land patent, one newspaper article, one image of the Assessment Book for Orange County (1915), and three historic aerial photographs were included in the body of the report (but not cited at the end of the report). They cited HRG’s evaluation report.

4. We also review whether the conclusions regarding historical significance (or lack thereof) are supported by substantial evidence, as defined in National Register Bulletin 15 and related relevant guidance. This includes assessing whether the property was evaluated for the correct area(s) and level(s) of significance (local, regional, state, or national), whether appropriate integrity aspects were considered, and whether the property retains sufficient integrity to convey its significance. We examine whether the subject property has been appropriately compared to similar properties within the same historic context and whether the narrative argument clearly establishes that the property is not only historic but significant under the applicable criteria.

In their February 12, 2025 report, Historic Resources Group (HRG) evaluated 31526 Valido Road within the historic context of “Homesteading and Agricultural Development in South Laguna (ca. 1909–1928)”. This context emphasizes the early 20th-century Euro-American settlement of South Laguna, specifically through land claims made under the Homestead Act of 1862. HRG links the property to this context through its association with William F. Egan, who filed a 40-acre homestead claim in 1910, constructed the original cabin around 1909, and actively farmed the land with his family into the late 1920s. The property’s significance is evaluated solely under California Register Criterion 1 (and National Register Criterion A) for its connection to early homesteading activity in the area. HRG does not assert eligibility under other criteria. The defined period of significance (ca. 1909–1928) reflects the timeframe during which the property developed and functioned as a working homestead.

While HRG identifies “Homesteading and Agricultural Development in South Laguna (ca. 1909–1928)” as the relevant historic context for evaluating the property, this context may be overextended and insufficiently substantiated when measured against the evaluative guidance provided in National Register Bulletin 15, which also underpins the California Register criteria. Bulletin 15 cautions that “a property must 456
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be more than simply associated with a historic trend; it must clearly illustrate that trend or be one of the most important properties associated with it.” In this case, HRG has not convincingly demonstrated that the Egan property rises to a level of distinctiveness, rarity, or illustrative clarity to justify significance under the broad theme of homesteading.

Although William Egan filed a 40-acre homestead claim in 1910 and constructed the original cabin ca. 1909, the Homestead Act was enacted nearly 50 years earlier in 1862, and many earlier and more robust examples of homesteading occurred in Southern Orange County—not specifically in what later became Laguna Beach. In fact, South Laguna was not formally named until 1934 and was not annexed into the City of Laguna Beach until 1987, calling into question whether it is appropriate to evaluate the property’s significance solely within the context of Laguna Beach’s local history, rather than in the broader regional context of Southern Orange County or unincorporated Orange County rural development.

Additionally, HRG does not provide sufficient comparative analysis with other known homestead properties in the region to support a claim that the Egan property is a particularly important or rare surviving example. Chronicle rightly critiques this point, emphasizing that the setting has been substantially altered, and without the surrounding agricultural context, the property no longer clearly conveys its claimed association with early 20th-century homesteading. While the residence may retain integrity in several aspects, the loss of setting—combined with an arguably generalized historic context and absence of a compelling comparative framework— undermines the strength of HRG’s argument for eligibility under Criterion 1.

5. Lastly, we assess whether the consultant’s conclusions are well reasoned, factually supported, and internally consistent, and we provide recommendations for improvement in future submittals when applicable.

Based on our review of the two independent historic resource assessments prepared by qualified professionals, GPA does not find sufficient evidence to support that the property at 31526 Valido Road meets the eligibility criteria for listing in either the California Register of Historical Resources or the National Register of Historic Places. As such, the property does not meet the definition of a “historical resource” under CEQA, nor does it appear to qualify as a historic resource under the City of Laguna Beach’s current Historic Preservation Ordinance, which requires that properties be either formally listed, eligible for listing, or voluntarily nominated by the property owner.

While HRG identified a potential association with early homesteading, the broader historic context presented does not convincingly support eligibility under Criterion 1, particularly in light of the compromised integrity of setting and the lack of rarity or 457
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comparative analysis. That said, GPA acknowledges there may be some potential for local historical significance under a more narrowly defined sub-context of early rural residential development in South Laguna, particularly given that the Egan residence is documented as one of the first homes constructed in the area.

However, under the City's current ordinance—which requires owner consent for local designation—the property cannot be formally recognized unless the owner voluntarily elects to pursue local listing. Should the owner wish to do so in the future, the potential eligibility of the property under local criteria may warrant further exploration within this refined context.

I want to thank you for the opportunity to provide an independent evaluation of the two reports submitted to the City regarding the potential historical significance of the property located at 31526 Valido Road. Should you have any questions, I can be reached at [email protected] or by phone at (310) 792-2690.

Sincerely,
Andrea Galvin
President
GPA Consulting
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DESIGN REVIEW BOARD STAFF REPORT
July 11, 2024
Agenda Item No. 5.7
Case No: Design Review 24-0658
Coastal Development Permit 24-0657
Project Location: 31526 Valido Road | APN: 056-062-25
Applicant: LCRA Architects, Architect
626-449-9698 | [email protected]
Property Owner: Chuanjie Zhou
Prepared By: Community Development Department
Garrett Wank | Associate Planner
(949) 464-6626 | [email protected]
Board Members within a
500’ Radius: None
RECOMMENDATION: Adopt Resolution 24-0658, approving Design Review 24-0658 and Coastal Development Permit 24-0657 for a new single-family residence, elevated decks, grading, landscaping, tandem parking, and third covered parking space and finding said action exempt from CEQA under Section 15303.

EXECUTIVE SUMMARY:

The Applicant, LCRA Architects, is requesting Design Review 24-0658 and Coastal Development Permit 24-0657. The proposed project demolishing an existing single-family residence and construction of a new single-family residence, upper-level additions, elevated decks, grading, landscaping, tandem parking, and third covered parking space (the “Project”). Staff has analyzed the Applicant’s request and believes that all of the findings of fact necessary for approval can be made for the requested entitlements. As a result, staff is recommending conditional approval of the proposed Project.

Attachment 14
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Design Review 24-0658
Coastal Development Permit 24-0657
July 11, 2024

PROPERTY AERIAL PHOTO

PROPERTY INFORMATION
Land Use Designation Village Low Density (1-7 DU/AC)
Zoning Designation R-1 Residential Low Density

ZONING REVIEW
The proposed project complies with applicable zoning standards and guidelines as shown in the summary table below.

Development Standard Required Existing Proposed Conforms Site Coverage 35%, 4924.85
SF

14.9%,
2096.58 SF

22.17%,
3119.54 SF
Yes
Landscape Open Space 34.29%, 4825
SF
79%,11,117
SF

53.91%,
7586 SF
Yes
Height (Lowest floor to top of roof) 29’ 11’8” 22’2” Yes Height (Above curb elevation) 17’6” 11’6” 17’6” Yes
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July 11, 2024

ZONING REVIEW
The proposed project complies with applicable zoning standards and guidelines as shown in the summary table below.

Setbacks
Front
Side (West)
Side (East)
Rear
Required
20’
9’-3 ¾ “
18-’7 ½ “
20’
Existing
3’11 ½ “
34-’2”
21’-8”
69’-8”
Proposed
20’
9’ -¾ “
18’-7 ½ “
58’
Yes
Yes
Yes
Yes
DISCUSSION/ANALYSIS:

Site History
The project site is currently developed with a single-family residence that is proposed to be demolished.

Proposed Project
The applicant proposes to demolish an existing 1,278 SF single-family residence and construct a new singlefamily residence (4,002 SF), elevated decks (461 SF), grading, landscaping, tandem parking, and third covered parking space.

ENTITLEMENTS: Included within this staff report is an analysis of the following entitlements: design review and a coastal development permit.

Design Review
The proposed new single-family residence, elevated decks, grading, landscaping, tandem parking, and third covered parking space require the approval of design review. (See LBMC Section25.05.040. Design review is governed by Laguna Beach Municipal Code Section 25.05.040. Design Review is considered by the Design Review Board at a duly noticed public hearing where the following findings are considered in relation to the proposed development:

Finding No. 1: Physical improvements and site developments related to the Project are designed and located in a manner in overall consistency with the design review criteria specified in Section 25.05.040(H), as set forth below:

1. Access. Conflicts between vehicles, pedestrians and other modes of transportation should be minimized by specifically providing for each applicable mode of transportation. Handicapped access shall be provided as required by applicable statutes.

Yes. The site will maintain access from Valido Road. Since the street frontage is less than 50 feet, an on street parking space is not required, pursuant to LBMC 25.53.006(C).

2. Design Articulation: Within the allowable building envelope, the appearance of building and retaining wall mass should be minimized. Articulation techniques including, but not limited to, 461
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separation, offsets, terracing and reducing the size of any one element in the structure may be used to reduce the appearance of mass.

Yes. Within the maximum allowable building envelope, the design of the structure utilizes variation of materials to reduce the appearance of mass, as shown in Figure 1 below.

Figure 1: Front Elevation Rendering

3. Design Integrity: Consistency with the applicant’s chosen style of architecture should be achieved by the use of appropriate materials and details. Remodels should be harmonious with the remaining existing architecture.

Yes. The modern/contemporary architectural style of the structure, with horizontal planes, is further achieved using a variety of materials and textures, including smooth stucco, horizontal siding, stone wall cladding, glass railings, and glazing.

4. Environmental Context: Development should preserve and, where possible, enhance the city’s scenic natural setting. Natural features, such as existing heritage trees, rock out-cropping, ridgelines and significant watercourses should be protected. Existing terrain should be utilized in the design and grading should be minimized.

Yes. The site does not contain significant natural features and no work is proposed within the watercourse area located on the site.

5. General Plan Compliance: The development shall comply with all applicable policies of the General Plan, including all of its elements, applicable specific plans, and the certified local coastal program.

Yes. The proposed project complies with the goals and policies of the General Plan below as evidenced in the Findings below.
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General Plan Policies
Land Use (LU) Policy 2.8 Require building design and siting to be compatible and integrated with natural topographic features, minimize significant alteration of natural topography and/or other significant onsite resources, and protect public views as specified in the Design Guidelines and the Landscape and Scenic Highways Resource Document.

The proposed project meets this policy as discussed in design articulation, environmental context, and neighborhood compatibility Design Criteria.

LU Policy 2.10 Maximize the preservation of coastal and canyon views (consistent with the principle of view equity) from existing properties and minimize blockage of existing public and private views. Best efforts should be made to site new development in locations that minimize adverse impacts on views from public locations (e.g., roads, bluff top trails, visitor-serving facilities, etc.).

The proposed project meets this policy as discussed in the view equity Design Criteria, and Design Review Finding #4, and the CDP findings below.

LU Policy 3.10 Require building design and siting to be compatible and integrated with natural topographic features, minimize significant alteration of natural topography or other significant onsite resources, and protect public views as specified in the Design Guidelines and Landscape and Scenic Highways Resource Document by maintaining the low-profile character of structures.

Require use of appropriate landscaping, special architectural treatments, and siting considerations for projects visible from major highways and arterial streets. Best efforts should be made to site new development in locations that minimize adverse impacts on views from public locations (e.g., roads, bluff-top trails, visitor-serving facilities, etc.).

The proposed project meets this policy as discussed in the view equity Design Criteria, and Design Review Finding #4, and the CDP findings below.

LU Policy 7.3 Design and site new development to protect natural and environmentally sensitive resources, such as areas of unique scenic quality, public views, and visual compatibility with surrounding uses and to minimize natural landform alterations. (Same as Policy 10.2.) GOAL:

Protect, preserve, and enhance the community’s natural resources.

Yes. The site does not contain significant natural features or environmentally sensitive resources and grading is mainly utilized to allow the structure to step with the natural topography. The proposed development is located more than 65 feet from the centerline of the watercourse/stream and impacts are not anticipated.
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6. Historic Preservation: Destruction or alteration to historic resources should be avoided whenever possible. See Chapter 25.45 for more information.

N/A. The project site is not considered a historic resource.

7. Landscaping: Landscaping shall be incorporated as an integrated part of the structure’s design and relate harmoniously to neighborhood and community landscaping themes. View equity shall be an important consideration in the landscape design. The relevant landscaping guidelines contained in the City’s “Landscape and Scenic Highways Resource Document” should be incorporated, as appropriate, in the design and planned maintenance of proposed landscaping.

Yes. The landscaping plan has been reviewed by the City’s landscape consultant for compliance with the City’s landscaping requirements and Landscape and Scenic Highways Resource Document.

8. Lighting and Glare: Adequate lighting for individual and public safety shall be provided in a manner which does not significantly impact neighboring properties. Reflective materials and appurtenances that cause glare or a negative visual impact (e.g., skylights, white rock roofs, highgloss ceramic tile roofs, reflective glass, etc.) should be avoided or mitigated to a level of insignificance in those locations where those surfaces are visible from neighboring properties.

Yes. All exterior lighting complies with the City’s Good Neighbor Lighting manual and no reflective materials are proposed.

9. Neighborhood Compatibility: Development shall be compatible with the existing development in the neighborhood and respect neighborhood character. Neighborhood character is the sum of the qualities that distinguish areas within the City, including historical patterns of development (e.g., structural heights, mass, scale or size), village atmosphere, landscaping themes and architectural styles.

Yes. The neighborhood is developed with single-family homes, with a variety of architectural styles, attached garages, and elevated decks. The mass and scale of the proposed residence is compatible with the existing residences in the surrounding neighborhood.

10. Pedestrian Orientation: Commercial development design shall enhance and encourage pedestrian uses. Incorporation of articulated building masses, compact open spaces and courtyards, mixed use developments, use of landscaping as part of design, and orientation to pedestrian access should be maximized.

N/A. Design Review Criteria for Pedestrian Orientation is related to commercial development and is not applicable to the proposed project.
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11. Privacy: The placement of activity areas (e.g., decks, picture windows and ceremonial or entertainment rooms) in locations that would result in a substantial invasion of privacy of neighboring properties should be minimized.

At the time of preparation of this report, staff has received one privacy concern from the adjacent property at 31538 West Street related to window placement. Staff recommends that the Board deliberate on privacy and consider additional conditions of approval to address any privacy concerns.

12. Public Art: Public art is encouraged and shall be displayed where feasible or required by the Art in Public Places ordinance.

N/A. Design Review Criteria for Public Art is related to commercial development and is not applicable to the proposed project.

13. Sign Quality: Signs shall be incorporated into the architecture of the structure and shall be made of high quality materials, be simple in design and be visually compatible with the surrounding physical environment in terms of color, scale and size. Use of natural materials in the construction of signs is encouraged.

N/A. Design Review Criteria for Signage is related to commercial development and is not applicable to the proposed project.

14. Sustainability: New development should consider architecture and building practices which minimize environmental impacts and enhance energy efficiency by: (a) reducing energy needs of buildings by proper site and structural design; (b) increasing the building’s ability to capture or generate energy; (c) using low-impact, sustainable and recycled building materials; (d) using the latest Best Management Practices regarding waste and water management; and (e) reducing site emissions.

Yes. New construction is required to meet Title 24 energy and Building Code requirements, which include insulated windows and energy efficient lighting. The applicant will be required to provide proof of compliance. Further, the applicant will be required to reuse, recycle, or divert at least 50 percent of the project’s construction and demolition debris.

15. Swimming Pools, Spas, and Water Features: Swimming pools, spas and water features shall be located, designed and constructed where: (a) geology conditions allow; (b) noise produced by circulatory mechanical pumps and equipment is mitigated; and (c) any associated fencing or other site improvements are compatible with neighboring properties.

N/A. No pool or spa is proposed as part of this application. 465
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16. View Equity: The development, including its landscaping, shall be designed to protect existing views from neighboring properties without denying the subject property the reasonable opportunity to develop as described and illustrated in the City’s “Design Guidelines.” The “Design Guidelines” are intended to balance preservation of views with the right to develop property.

At the time of preparation of this report, staff have not received comments from neighbors regarding view equity concerns. The project is sited adjacent to a large open space area and few properties have views overlooking the project. For this reason, staff does not anticipate a significant impact to coastal views or view equity. After public testimony, the DRB should determine whether this criterion has been met.

Finding No. 2. The physical improvements and site developments related to the Project are designed and located in a manner in overall consistency with all other applicable design guidelines.

Yes. The project is consistent with the Residential Design Review Guidelines, as explained above.

Finding No. 3. The physical improvements and site developments related to the Project are characterized by appropriately scaled development, diverse and unique architectural designs, pedestrian orientation, and sensitivity to the natural conditions of the site.

Yes. The project design and architecture are appropriately scaled and diverse, as described in the design integrity and neighborhood compatibility Design Criteria above.

Finding No. 4. The project is consistent with any specific plan or any other specific zoning design review criteria.

Yes. The project site is not located within a specific plan and the R-1 zoning does not contain any other specific design review criteria. The project conforms to the Architectural Guidelines, including avoiding major disparities of height and bulk with adjacent structures, use of appropriate colors, and appropriate scale, detail and articulation of the structure.

Coastal Development Permit
The proposed new single-family Residence, elevated decks, grading, landscaping, tandem parking, and third covered parking space requires the approval of a coastal development permit. (See LBMC Section

25.07.004.) Coastal Development Permits are governed by Laguna Beach Municipal Code Chapter 25.07.

A Coastal Development Permit is considered by the Design Review Board at a duly noticed public hearing where the following findings are considered in relation to the proposed development:

Finding No. 1: The project is in conformity with all the applicable provisions of the certified local coastal program, including the following review criteria:

1. The proposed development will not encroach upon any existing physical accessway legally utilized by the public or any proposed public accessway identified in the adopted local coastal program land use plan.
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Yes. The proposed development will occur on a property accessible from an improved public street (Valido Road). The project is not encroaching on a public accessway, and no new access is proposed.

2. The proposed development will not adversely affect marine resources, environmentally sensitive areas, or archaeological or paleontological resources.

Yes. There are no known marine resources, environmentally sensitive areas, archeological, or paleontological resources in the project area. The project site is located within an established residential neighborhood. The proposed development is located more than 65 feet from the centerline of the watercourse/stream and impacts are not anticipated.

3. The proposed development will not adversely affect recreational or visitor-serving facilities or coastal scenic resources.

Yes. The subject property is located within an established residential neighborhood and the proposed addition and remodel of the existing single-family dwelling will be on private property. No impacts will occur to recreational or visitor-serving facilities or coastal scenic resources in the area.

4. The proposed development will be sited and designed to prevent adverse impacts to environmentally sensitive habitats and scenic resources located in adjacent parks and recreation areas, and will provide adequate buffer areas to protect such resources.

Yes. The subject property is located within an established residential neighborhood and not immediate to environmentally sensitive habitats or scenic resources in adjacent areas. The proposed development is located more than 65 feet from the centerline of the watercourse/stream and impacts are not anticipated.

5. The proposed development will minimize the alterations of natural landforms and will not result in undue risks from geological and erosional forces and/or flood and fire hazards.

Yes. The project site does not contain any significant natural landforms. Grading is mostly limited to the structure’s footprint and done so to create safe access to the property. The Project will not result in undue risk from flood or fire hazards.

6. The proposed development will be visually compatible with the character of surrounding areas, and where feasible, will restore and enhance visual quality in visually degraded areas.

Yes. As described in the “design articulation” and “neighborhood compatibility” criteria above, the proposed development is well-articulated and is architecturally compatible with the surrounding neighborhood in an area that is not visually degraded.

7. The proposed development will not have any adverse impacts on any known archaeological or paleontological resource.
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N/A. There are no known archaeological or paleontological resources in the project area.

8. The proposed development will be provided with adequate utilities, access roads, drainage and other necessary facilities.

Yes. The existing site is within an established residential neighborhood with connections to necessary utilities, drainage, and other facilities.

9. Other public services, including, but not limited to, solid waste and public roadway capacity have been considered and are adequate to serve the proposed development.

Yes. The existing site is within an established residential neighborhood with access to other public services.

The project is consistent with all applicable policies of the Certified LCP.

LCP COASTAL VIEW POLICIES (CDP)
Land Use Element (LU) Policy 2.8 Require building design and siting to be compatible and integrated with natural topographic features, minimize significant alteration of natural topography and/or other significant on-site resources, and protect public views as specified in the Design Guidelines and the Landscape and Scenic Highways Resource Document.

The proposed project is designed to integrate with the existing topography of the site and there will be no impact to any public views. No development is proposed within the watercourse area existing at the northeast corner of the property.

LU Element Policy 2.9 Require the use of appropriate landscaping, special architectural treatments, and/or siting considerations to protect public views for projects visible from major highways and arterial streets.

As described in the “design integrity” and “neighborhood compatibility” criteria above, the proposed project will be architecturally compatible with the surrounding neighborhood.

LU Element Policy 2.10 Maximize the preservation of coastal and canyon views (consistent with the principle of view equity) from existing properties and minimize blockage of existing public and private views. Best efforts should be made to site new development in locations that minimize adverse impacts on views from public locations (e.g., roads, bluff top trails, visitor-serving facilities, etc.) Policy 2.10 includes: Action 2.10.1 Discourage the addition of second stories in established neighborhoods where view equity has historically been achieved through one-story construction.

The Project will not impact coastal views or view equity as described in “view equity” criteria above. 468
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Design Review 24-0658
Coastal Development Permit 24-0657
July 11, 2024

LUE Policy 3.10 Require building design and siting to be compatible and integrated with natural topographic features, minimize significant alteration of natural topography or other significant onsite resources, and protect public views as specified in the Design Guidelines and Landscape and Scenic Highways Resource Document by maintaining the low-profile character of structures.

Require use of appropriate landscaping, special architectural treatments, and siting considerations for projects visible from major highways and arterial streets. Best efforts should be made to site new development in locations that minimize adverse impacts on views from public locations (e.g., roads, bluff-top trails, visitor-serving facilities, etc.).

Policy 3.10 requires protection of public views as specified in the Design Guidelines. The Design Guidelines require View Equity for impacts to public views and require maintenance of view corridors.

View Equity is defined as: View equity means achievement of a fair, reasonable and balanced accommodation of views and competing obstructions such as structures, trees and/or vegetation, privacy and the use and enjoyment of property.

The Design Review Guidelines refers to Public Views:

15.6 Maintain view corridors when feasible.
∙Consider opportunities for public views.
∙Locate a building to retain view opportunities through side yards.

The project is sited adjacent to a large open space area and few properties have views overlooking the project. Therefore, the proposed single-family dwelling will not impact coastal views or view equity as described in “view equity” criteria above.

Finding No. 2. Any development located between the sea and the first public road paralleling the sea is in conformity with the certified local coastal program and with the public access and public recreation policies of Chapter 3 of the Coastal Act.

The project site is not located between the sea and the first public road paralleling the sea and does not impact existing public access or public recreation facilities. Additionally, the subject site is zoned residential and is not suitable for recreational uses identified in Chapter 3 of the Coastal Act.

Therefore, the finding that the project is in conformity with the public access and public recreation policies of Chapter 3 of the Coastal Act can be made.

ENVIRONMENTAL IMPACT:

In accordance with the California Environmental Quality Act (CEQA) guidelines, the project is categorically exempt pursuant to Section 15303 - New Construction or Conversion of Small Structures, in that the project consists of construction and location of limited numbers of new, small structures There is no evidence of any unusual or special conditions that would result in a significant effect on the environment.

This project fits within the Class 3 exemption because it is a single-family dwelling on an existing legal building site.
469
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Design Review 24-0658
Coastal Development Permit 24-0657
July 11, 2024

Further, none of the exceptions outlined in CEQA Guidelines section 15300.2 apply. The project site does not contain any environmentally sensitive areas. There are no unusual circumstances resulting in a significant impact on the environment as the project is similar in scope to other developed properties in the surrounding developed neighborhood. There will be no cumulative impact resulting from successive projects of the same type in the same place, over time. There are no unusual circumstances resulting in a significant impact on the environment. There will be no damage to scenic resources, including trees, historic buildings, rock outcroppings or similar resources, within a highway officially designated as a state scenic highway. The project is not located on a hazardous waste site, or any other site included on a list compiled pursuant to Government Code section 65962.5. The project will not result in significant adverse impacts to historical resources as defined by CEQA. Consequently, additional environmental analysis is not necessary to meet the requirements of the CEQA.

Staff will cause to be filed a Notice of Exemption (NOE) with the County Recorder’s Office should the Project receive final approval.

RECOMMENDATION:

It is recommended that the Board, by motion, adopt a resolution (Attachment 1) approving Design Review 24-0658 and Coastal Development Permit 24-0657 and finding said action exempt from CEQA.

NOTIFICATION:

Pursuant to Title 25 (Zoning) Public Notice, a public hearing notice has been mailed at least twenty-one (21) days prior to the hearing date in accordance with Title 25. In addition, a public hearing notice has been posted on the project site at least 10 days in advance of the hearing date ATTACHMENT(S):

Attachment 1 – Resolution No. 24-0658
Attachment 2 – Soils Report
Attachment 3 – Public Commentary
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PROJECT SUMMARY PROJECT DATA Project Address 31526 Valido Road, CA 92651 Project Description New Single Family Residence APN 056-062-25 Zone R-1 NARRATIVE DESCRIPTION: DEMOLITION OF EXISTING SINGLE STORY RESIDENCE, WITH DETACHED ONE CAR GARAGE AND LARGE WORKSPACE, FOR THE CONSTRUCTION OF A NEW 4,002 SF, TWO-STORY SINGLE FAMILY RESIDENCE WITH ATTACHED 619 SF GARAGE SHEET Sheet Architecture Description A-0.0 COVER SHEET A-0.1 PROPOSED SITE PLAN A-SP A-2.0 PROPOSED ELEVATIONS Legal Description SEC 5 T 8 R 8 POR SW1/4 NW1/4 PIN 1064 A-1.0 CONTACT INFORMATIONProperty Owner Hongbin Peng [email protected] 1040 Oak Grove Avenue San Marino, CA 91008 (626) 503-4395 Architect LCRA Architects [email protected] 35 Hugus Alley #220 Pasadena, CA 91103 (626) 440-9698 Construction Type V Occupancy A-1.1 A-2.1 A-1.2 PROPOSED FIRST FLOOR PLAN PROPOSED SECOND FLOOR PLAN PROPOSED ELEVATIONS STAKING PLAN Landscape Architecture Description L-1 HARDSCAPE R-3 / U Civil Engineer TOAL Engineering, Inc. [email protected] 139 Avenida Navarro San Clemente, CA 92672 (949) 492-8586 Landscape Architect TGP Inc., Landscape Architecture [email protected] P.O.Box 704 Montrose, CA 91021 (818) 797-5914 A-0.2 FIRE DEPARTMENT SITE ACCESS PLAN A-0.3 PROPOSED SITE LIGHTING PLAN PROPOSED ROOF PLAN A-1.3 FIRST FLOOR AREA CALCULATIONS A-1.4 SECOND FLOOR AREA CALCULATIONS A-2.3 PROPOSED COLORED ELEVATIONS A-2.4 PROPOSED COLORED ELEVATIONS Civil Engineering Description TP-01 TOPOGRAPHIC AND BOUNDARY SURVEY L-2 SITE CHARACTERIZATION/NOTES C-1 GRADING PLAN A-0.4 OPEN SPACE DIAGRAM L-3 PLANTING PLAN A-4.0 3D VIEWS A-2.2 ELEVATION BUILDING ENVELOPE L-4 IRRIGATION PLAN L-5 LANDSCAPE OPEN SPACE PLAN A-3.0 PROPOSED SECTIONS 31526 VALIDO ROAD 31526 VALIDO ROAD -April 22, 2024 COVER SHEET A-0.0 Cleared for DRB
07/02/2024
Signature __________
Date _____________ 01/18/2024
GARAGE 225.15 ROOF RIDGE 231.87 TOP OF ROOF 231.93 TOP OF ROOF235.74 ROOF RIDGE 237.41 ROOF RIDGE 247.97 TOP OF ROOF ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE 239.10' T.O. PARAPET 239.10' T.O. PARAPET 221.60' MIDPOINT FRONT P.L. C.L. PRIVATE EASEMENT 213.40' 176.20' 227.00' 195.90' EXISTING 1-STORY RESIDENCE EXISTING 1-CAR GARAGE 2-STORY CUSTOM HOME (FIRST FLOOR FOOTPRINT) STREET CENTERLINE 31526 VALIDO ROAD -April 22, 2024 PROPOSED SITE PLAN A-0.1 SCALE: 1'-0" = 1/8" GARAGE
32'-012"
9'-434" 20'-0" 20'-0" 20'-0" FYSB
SYSB RYSB 57'-8"
13'-0" A-ROOF-SLOPE 9 Continuous Roof slope symbol 100% 0.178 BUILT-UP FLAT ROOF 1/4"/FT. SLOPE PARAPET @ 228.77' BUILT-UP FLAT ROOF 1/4"/FT. SLOPE BUILT-UP FLAT ROOF 1/4"/FT. SLOPE PARAPET @ 239.10' PARAPET @ 239.10' PARAPET @ 239.10' PARAPET @ 239.10' PARAPET @ 239.10' 238.60' 217.67' F.F. 217.50' F.F. 218.67' F.F. 218.67' F.F. 219.00' F.F. SOLAR READY AREA PARAPET @ 239.10' 9'-434"
SYSB 150'-0" 140'-2" 140'-10" 140'-10" 3'-0"
3'-0" 3'-0" FYSB 3-CAR GARAGE ADJACENT RESIDENCE ADJACENT RESIDENCE 2-STORY CUSTOM HOME (FIRST FLOOR FOOTPRINT) A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks WEST STREET TOTO LOMA ROAD 31532 31538 31532 31521 31551

VALIDO ROAD
GARAGE 31526 FIRE HYDRANT 193'-0" 31526 VALIDO ROAD -April 22, 2024 FIRE ACCESS PLAN FIRE HYDRANT LOCATION FIRE DEPARTMENT SITE ACCESS PLAN A-0.2 3 LAGUNA BEACH FIRE DEPARTMENT REVIEW NOTES CODE (2022) DESCRIPTION CONFORMS REMARKS CFC 503.1.1 APPROVED FIRE APPARATUS ACCESS ROADS SHALL BE PROVIDED FOR EVERY FACILITY, BUILDING OR PORTION OF A BUILDING HEREAFTER CONSTRUCTED OR MOVED INTO OR WITHIN THE JURISDICTION. THE FIRE APPARATUS ACCESS ROAD SHALL COMPLY WITH THE REQUIREMENTS OF THIS SECTION AND SHALL EXTEND TO WITHIN 150 FEEt OF ALL PORTIONS OF THE FACILITY AND ALL PORTIONS OF THE EXTERIOR WALLS OF THE FIRST STORY OF THE BUILDING AS MEASURED BY AN APPROVED ROUTE AROUND THE EXTERIOR OF THE BUILDING OR FACILITY. YES SEE PLAN CFC 503.2.1 FIRE APPARATUS ACCESS ROADS SHALL HAVE AN UNOBSTRUCTED WIDTH OF NOT LESS THAN 20 FEET, EXCLUSIVE OF SHOULDERS, EXCEPT FOR APPROVED SECURITY GATES IN ACCORDANCE WITH AND AN UNOBSTRUCTED VERTICAL CLEARANCE OF NOT LESS THAN 13 FEET 6 INCHES. YES SEE PLAN AND FIRE PROTECTION NOTES CFC 503.2.5 DEAD-END FIRE APPARATUS ACCESS ROADS IN EXCESS OF 150 FEET (45 720 MM) IN LENGTH SHALL BE PROVIDED WITH AN APPROVED AREA FOR TURNING AROUND FIRE APPARATUS. YES SEE PLAN CFC 504.1 EXTERIOR DOORS AND OPENINGS REQUIRED BY THIS CODE OR THE CALIFORNIA BUILDING CODE SHALL BE MAINTAINED READILY ACCESSIBLE FOR EMERGENCY ACCESS BY THE FIRE DEPARTMENT. AN APPROVED ACCESS WALKWAY LEADING FROM FIRE APPARATUS ACCESS ROADS TO EXTERIOR OPENINGS SHALL BE PROVIDED WHERE REQUIRED BY THE FIRE CODE OFFICIAL. CFC 506.1 WHERE ACCESS TO OR WITHIN A STRUCTURE OR AN AREA IS RESTRICTED BECAUSE OF SECURED OPENINGS OR WHERE IMMEDIATE ACCESS IS NECESSARY FOR LIFE-SAVING OR FIRE-FIGHTING PURPOSES, THE FIRE CODE OFFICIAL IS AUTHORIZED TO REQUIRE A KEY BOX TO BE INSTALLED IN AN APPROVED LOCATION CFC 507.3 FIRE FLOW. FIRE FLOW REQUIREMENTS FOR BUILDINGS OR PORTIONS OF BUILDINGS AND FACILITIES SHALL BE DETERMINED BY AN APPROVED METHOD OR APPENDIX B. TO BE COMPLETED BY WATER DISTRICT. 123456 FIRE LANE IDENTIFICATION MUST INCLUDE ALL RED CURB AND SIGNAGE AS APPLICABLE. PROVIDE A MINIMUM 3 FEET WIDE, ALL WEATHER, NON-COMBUSTIBLE ACCESS PATH AROUND THE STRUCTURE, WITH A MAXIMUM SLOPE NOT TO EXCEED 10%. FIRE HYDRANT SYSTEMS AND SPACING SHALL COMPLY WITH CURRENT ADOPTED CFC APPENDIX C, WITH A MAXIMUM DISTANCE FROM FRONTAGE TO HYDRANT NOT TO EXCEED 250 FEET. BRUSH CLEARANCE: PRIOR TO COMMENCEMENT OF ANY CONSTRUCTION, ALL APPLICABLE PROVISIONS PERTAINING TO BRUSH CLEARANCE CONTAINED IN THE UNIFORM FIRE CODE SHALL BE FULLY COMPLIED WITH TO THE SATISFACTION OF THE LAGUNA BEACH FIRE DEPARTMENT. PROVIDE FIRE SPRINKLED SYSTEM BASED ON THE MOST RECENT FIRE CODE. RECESSED KEY BOX. ACCESS TO OR WITHIN A STRUCTURE WHEN AREA IS RESTRICTED BECAUSE OF A SECURE OPENING, A KEY BOX MUST BE INSTALLED FOR ACCESS IN LIFE-SAVING AND OR FIREFIGHTING PURPOSE. HOSE PULL. PROVIDE A MINIMUM 3 FEET WIDE, AL WEATHER, NON-COMBUSTIBLE ACCESS PATH AROUND THE STRUCTURE. FIRE DEPARTMENT NOTES (CONT'D): PROJECT ADDRESS 31526 VALIDO ROAD, CA 92651 PROJECT DESCRIPTION NEW SINGLE FAMILY RESIDENCE APN 056-062-25 ZONE R-1 DEMOLITION OF EXISTING SINGLE STORY RESIDENCE, WITH DETACHED ONE CAR GARAGE AND LARGE WORKSPACE, FOR THE CONSTRUCTION OF A NEW 3,947 SF, TWO-STORY SINGLE FAMILY RESIDENCE WITH ATTACHED 664 SF GARAGE LEGAL DESCRIPTION SEC 5 T 8 R 8 POR SW1/4 NW1/4 PIN 1064 CONSTRUCTION TYPE V OCCUPANCY R-3 / U FIRST FLOOR SECOND FLOOR TOTAL LIVABLE GARAGE 1,948 S.F. 2,054 S.F. 4,002 S.F. 619 S.F. A. MAINTAIN JOBSITE SAFETY DURING CONSTRUCTION AS PER CHAPTER 33 OF THE 2022 CALIFORNIA FIRE CODE. B. COMPLETE FIREFIGHTER ACCESS AROUND THE BUILDING IS REQUIRED, AND MUST BE IN COMPLIANCE WITH THESE APPROVED PLANS. SEE THIS SHEET FOR DETAILS. THIS IS SUBJECT TO FINAL FIRE INSPECTION AND REQUIRED APPROVAL PRIOR TO OCCUPANCY. C. ADDRESS NUMBERS MUST BE PLACED ON THE EXTERIOR FACING THE STREET ADDRESSED TO. MINIMUM SIZE OF NUMBERS IS 4", AND THEY MUST CONTRAST WITH THE BACKGROUND. D. FOR FIRE DEPARTMENT INSPECTIONS, CALL (949)497-0352 AT LEAST 3 DAYS IN ADVANCE TO SCHEDULE. E. ALL STAIRS TO COMPLY WITH CBC, CHAPTER 10, FOR RISE/RUN. F. A SEPARATE (DEFERRED) SUBMITTAL FOR FIRE SPRINKLERS IS REQUIRED. SYSTEM DESIGN MUST COMPLY WITH THE 2022 CFC AND 2022 NFPA 13 STANDARD. PLANS MUST BE DESIGNED AND INSTALLED BY A QUALIFIED FIRE PROTECTION CONTRACTOR. PLANS SHALL BE SUBMITTED TO AND APPROVED BY THE LBFD, WITH PERMIT ISSUED AND APPROPRIATE INSPECTIONS CONDUCTED. G. ALL EXTERIOR FIRE PLACES AND FIRE PITS MUST BE GAS FIRED ONLY. NO SOLID FUEL IS ALLOWED PER THE LBFD MUNICIPAL CODE. FIRE PLACES AND FIRE PITS MUST BE A MINIMUM OF 10 FEET FROM COMBUSTIBLE VEGETATION. NARRATIVE DESCRIPTION: PROJECT SUMMARY: FIRE PROTECTION PLAN NOTES: FIRE DEPARTMENT NOTES: CODE COMPLIANCE: THIS PROJECT SHALL COMPLY WITH ALL 2022 CALIFORNIA FIRE CODE STANDARDS, 2022 CALIFORNIA RESIDENTIAL (CRC); 2022 ELECTRICAL, ENERGY (ENS), MECHANICAL (CMC), PLUMBING (CPC); AND 2022 CALIFORNIA GREEN BUILDING STANDARDS WITH LOCAL AMENDMENTS, CODES AND ORDINANCES. ADDITIONAL COMPLIANCE: NPDES, SUSMP AND BMP REQUIREMENTS DIG ALAERT FIRE PREVENTION BUREAU CONDITIONS: 1. THIS PROPERTY IS IN THE VERY HIGH FIRE HAZARD SEVERITY ZONE (VHFHSZ). IT SHALL COMPLY WITH ALL APPLICABLE REQUIREMENTS OF THE 2022 CALIFORNIA FIRE CODE CHAPTER 49 AND LAGUNA BEACH CITY'S FUEL MODIFICATION STANDARDS FOR DEVELOPMENT. 2. THIS PROJECT SHALL COMPLY WITH ALL 2022 CALIFORNIA FIRE CODE STANDARDS. 3. IN ACCORDANCE WITH 2022 CALIFORNIA FIRE CODE 106, ALL REQUIRED FIRE PROTECTION EQUIPMENT PLANS SHALL BE A DIFFERENT SUBMITTAL 4. EXTERIOR FIR PIT SHALL COMPLY WITH 2022 CALIFORNIA FIRE CODE 307.2 AS AMENDED BY LAGUNA BEACH MUNICIPAL CODE 15.01.030. 7 3 1 1 2 24 4 7 7 11 06 GARAGE 2-STORY CUSTOM HOME (SECOND FLOOR FOOTPRINT) ADJACENT RESIDENCE ADJACENT RESIDENCE LL LL LL LL UL UL UL LL/UL LL/UL LL/UL LL/UL 2 1 2 2 2 2 1 1 1 UL LL LL LL LL LL LL 31526 VALIDO ROAD -April 22, 2024 PROPOSED SITE LIGHTING A-0.3 SCALE: 1'-0" = 1/8" 1. LOWER LEVEL DOOR TO EXTERIOR 2. UPPER LEVEL DOOR TO EXTERIOR SITE LIGHTING NOTES: TOTAL QUANTITY - LED SOFFIT DOWNLIGHT FIXTURE TOTAL QUANTITY - LED WALL MOUNT LIGHT FIXTURE SITE LIGHTING LEGEND: LL - FIRST FLOOR UL - SECOND FLOOR EXTERIOR BUILDING LIGHTING: EXISTING EGRESS DOORS EXISTING EGRESS DOORS EXISTING FIXTURE COUNT PROPOSED FIXTURE COUNT FIXTURE TYPE WATTAGE LUMENS TOTAL LED WALL MOUNT 16 1,424 LED SOFFIT DOWNLIGHT 15 1,100 LL/UL - FIRST AND SECOND FLOOR QUANTITY 111122 TOTAL TOTAL 176 W 165 W 341 W 15,664 LM 12,100 LM 27,764 LM COMMENTS 24 422 3. PLEASE REFER TO LANDSCAPE SHEET L-1 HARDSCAPE PLAN FOR ADDITIONAL LANDSCAPE LIGHTING INFORMATION. 2-STORY CUSTOM HOME (FIRST FLOOR FOOTPRINT) 3'-3" 3'-412" 6'-012" 3'-0" OPEN SPACE D (118 S.F. ) OPEN SPACE E (113 S.F. ) OPEN SPACE G (71 S.F. ) OPEN SPACE REQUIRED - 34.29% (14,071 S.F. X 34.29)/100 = 4,824.95 S.F. TOTAL OPEN SPACE PROVIDED - (10,699 S.F.) OPEN SPACE A OPEN SPACE B OPEN SPACE C OPEN SPACE D 7,373 S.F. TOTAL OPEN SPACE (LANDSCAPE) 8,155 S.F. TOTAL OPEN SPACE REQUIRED - (4,825 S.F.) OPEN SPACE A ( 7,373 S.F. ) 6'-7" 32'-912" 86'-1" 84'-10" 63'-1" 50'-4" 66'-512" 43'-712" 16'-012" 9'-812" 9'-7"10'-11" 6'-10" PLEASE REFER TO LANDSCAPE SET FOR ADDITIONAL INFORMATION OPEN SPACE B (237 S.F. ) 49'-4" 7'-0"
9'-1" OPEN SPACE E OPEN SPACE H ( 11 S.F. ) OPEN SPACE C (137 S.F. ) OPEN SPACE F ( 88 S.F. ) OPEN SPACE I ( 7 S.F. ) OPEN SPACE F OPEN SPACE G OPEN SPACE H OPEN SPACE I 118 S.F. 113 S.F. 237 S.F. 137 S.F. 11 S.F. 88 S.F. 7 S.F. 71 S.F. TOTAL OPEN SPACE (HARDSCAPE) 2,544 S.F. TOTAL OPEN SPACE 10,699 S.F. 31526 VALIDO ROAD -April 22, 2024 OPEN SPACE DIAGRAM A-0.4 SCALE: 1'-0" = 1/8" 3-CAR
GARAGE
GREAT
ROOM

KITCHEN

FOYER SIDE ENTRY
PANTRY

DEN/OFFICE
PDR.

BEDROOM 4
BA. 4

COURTYARD

FIRST FLOOR

SECOND FLOOR
TOTAL LIVABLE 4,002 S.F.

GARAGE
1,944 S.F.
619 S.F.
2,054 S.F.
217.67' F.F.
217.50' F.F.
218.67' F.F. 218.67' F.F.
219.00' F.F.
31526 VALIDO ROAD
-
April 22, 2024
PROPOSED FIRST FLOOR PLAN A-1.0
SCALE: 1'-0" = 1/4"
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PRIMARY

PRIMARY
BATH
W.I.C.

LOFT
BEDROOM 2
BEDROOM 3
BATH 2
W.I.C.

W.I.C.

LAUNDRY
BATH 3
DECK

BALCONY
228.67' F.F.
228.50' F.F.
228.67' F.F.
228.50' F.F.

WRAPAROUND DECK
228.50' F.F.
31526 VALIDO ROAD
-
April 22, 2024
PROPOSED SECOND FLOOR PLAN A-1.1
SCALE: 1'-0" = 1/4"
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A-ROOF-SLOPE 9 Continuous Roof slope symbol 100% 0.178 ROOF PLAN BUILT-UP FLAT ROOF 1/4"/FT. SLOPE PARAPET @ 228.77' BUILT-UP FLAT ROOF 1/4"/FT. SLOPE BUILT-UP FLAT ROOF 1/4"/FT. SLOPE PARAPET @ 239.10' PARAPET @ 239.10' PARAPET @ 239.10' PARAPET @ 239.10'
PARAPET @ 239.10' 238.60' 238.60' 228.77' 228.77' 238.60' 238.60' 238.60' 228.27' SOLAR READY AREA PARAPET @ 239.10' 31526 VALIDO ROAD -April 22, 2024 PROPOSED ROOF PLAN A-1.2 SCALE: 1'-0" = 1/4" G1 G2 C1 C3 C4 L1 L3 L6 L4 L7 L5 L2 L8 L9 C2G3 G4 LIVABLE (L) LEGEND DECK/BALCONY (D) GARAGE (G) MECHANICAL (M) CIRCULATION/STORAGE [LIVABLE] (C) 31526 VALIDO ROAD -April 22, 2024 FIRST FLOOR AREA CALCULATIONS A-1.3 SCALE: 1'-0" = 1/4" FLOOR AREA CALCULATIONS FIRST FLOOR SECOND FLOOR LIVABLE LIVABLE LOCATION SQ. FT. LOCATION SQ. FT. L1 996.79 L1 388.92 L2 243.48 L2 363.99 L3 167.51 L3 334.34 L4 92.66 L4 253.70 L5 55.77 L5 225.52 L6 40.49 L6 200.35 L7 8.58 L7 110.63 L8 8.21 L8 3.96 L9 5.48 L9 1.81 TOTAL 1618.97 TOTAL 1883.22 CIRCULATION (LIVABLE) CIRCULATION (LIVABLE) LOCATION SQ.FT. LOCATION SQ. FT. C1 190.48 C1 118.13 C2 62.84 C2 27.44 C3 56.63 C3 23.52 C4 18.75 C4 1.98 TOTAL 328.70 TOTAL 171.07 GARAGE DECK/BALCONY LOCATION SQ. FT. LOCATION SQ. FT. G1 436.59 D1 215.87 G2 177.29 D2 114.26 G3 2.77 D3 80.99 G4 2.09 D4 36.76 TOTAL 618.74 D5 16.12 TOTAL 464.00 MECHANICAL (ELEC. PANEL) LOCATION SQ. FT. TOTAL LIVABLE, 2ND 2054.29 M1 0.00 TOTAL 0.00 TOTAL LIVABLE, 1ST 1947.67 TOTAL LIVABLE 4001.96 228.67' F.F. 228.50' F.F. 228.67' F.F. 228.50' F.F. 228.50' F.F. D2 D1 D3 D5 D4 L1 L2 L3 L4 L5 L6 L7 C1 C3C2 C4 L8 L9 LIVABLE (L) LEGEND DECK/BALCONY (D) GARAGE (G) MECHANICAL (M) CIRCULATION/STORAGE [LIVABLE] (C) 31526 VALIDO ROAD -April 22, 2024 SECOND FLOOR AREA CALCULATIONS A-1.4 SCALE: 1'-0" = 1/4" FLOOR AREA CALCULATIONS FIRST FLOOR SECOND FLOOR LIVABLE LIVABLE LOCATION SQ. FT. LOCATION SQ. FT. L1 996.79 L1 388.92 L2 243.48 L2 363.99 L3 167.51 L3 334.34 L4 92.66 L4 253.70 L5 55.77 L5 225.52 L6 40.49 L6 200.35 L7 8.58 L7 110.63 L8 8.21 L8 3.96 L9 5.48 L9 1.81 TOTAL 1618.97 TOTAL 1883.22 CIRCULATION (LIVABLE) CIRCULATION (LIVABLE) LOCATION SQ.FT. LOCATION SQ. FT. C1 190.48 C1 118.13 C2 62.84 C2 27.44 C3 56.63 C3 23.52 C4 18.75 C4 1.98 TOTAL 328.70 TOTAL 171.07 GARAGE DECK/BALCONY LOCATION SQ. FT. LOCATION SQ. FT. G1 436.59 D1 215.87 G2 177.29 D2 114.26 G3 2.77 D3 80.99 G4 2.09 D4 36.76 TOTAL 618.74 D5 16.12 TOTAL 464.00 MECHANICAL (ELEC. PANEL) LOCATION SQ. FT. TOTAL LIVABLE, 2ND 2054.29 M1 0.00 TOTAL 0.00 TOTAL LIVABLE, 1ST 1947.67 TOTAL LIVABLE 4001.96 FYSB 20'-0"
17'-6" ABOVE

FRONT ELEVATION HEIGHT
21'-2" ABOVE
F.G. ELEVATION HEIGHT 221.60' 239.10' 229.13'
PROPERTY LINE FRONT ELEVATION 228.77' 219.00' F.G. 218.00' F.G. 14'-8"

ABOVE NATURAL GRADE
17'-6" ABOVE
FRONT ELEVATION HEIGHT 239.10' 221.60' 217.00' F.G. FYSB 20'-0" 21'-8" ABOVE
F.G. ELEVATION HEIGHT
PROPERTY LINE REAR ELEVATION MULTI-SLIDE POCKETING DOORS - LA CANTINA, SHADOW BLACK, DUAL GLAZED ELEVATION NOTES DOORS AND WINDOWS - MARVIN, ULTIMATE, ALUMINUM CLAD WOOD, EBOBY SMOOTH FINISH STUCCO - BENJAMIN MOORE, OFF-WHITE COLLECTION, WHITE HERON, OC-57 123 4 FIBER CEMENT STONE - EQUITONE [TECTIVA], TE20 COLOR, FINE SANDED LINES FIBER CEMENT SIDING - HARDIE, ARCHITECTURAL COLLECTION, FINE SAND, BENJAMIN MOORE, CLASSIC COLORS, STAMPEDE, 979 56 789 10 PAINTED METAL CANOPY - BENJAMIN MOORE, COLOR PREVIEW COLLECTION, JET BLACK, 2120-10 GARAGE DOOR - STERLING, FLUSH PANEL, SLATE GRAY EXTERIOR LIGHT FIXTURE - WAC LIGHTING, STAG, OUTDOOR LIGHTING WALL SCONCE, BLACK GLASS RAILING - COVER GLASS USA, CLEARLINE, FRAMELESS BASE SHOE SYTEM WITH NANORAIL TOP EDGE CAPPING DOUBLE-SIDED FIREPLACE - ACCUCRAFT FIREPLACE SYSTEMS, A-SS-5-10, SIGNATURE SERIES 31526 VALIDO ROAD -April 22, 2024 PROPOSED ELEVATIONS A-2.0 239.10' 218.00' F.G.
21'-8" ABOVE
F.G. ELEVATION HEIGHT

PROPERTY LINE
PROPERTY LINE RIGHT ELEVATION 221.60'
21'-8" ABOVE
F.G. ELEVATION HEIGHT SYSB 9'-4 3/4" SYSB 9'-4 3/4"

PROPERTY LINE
PROPERTY LINE LEFT ELEVATION MULTI-SLIDE POCKETING DOORS - LA CANTINA, SHADOW BLACK, DUAL GLAZED ELEVATION NOTES DOORS AND WINDOWS - MARVIN, ULTIMATE, ALUMINUM CLAD WOOD, EBOBY SMOOTH FINISH STUCCO - BENJAMIN MOORE, OFF-WHITE COLLECTION, WHITE HERON, OC-57 123 4 FIBER CEMENT STONE - EQUITONE [TECTIVA], TE20 COLOR, FINE SANDED LINES FIBER CEMENT SIDING - HARDIE, ARCHITECTURAL COLLECTION, FINE SAND, BENJAMIN MOORE, CLASSIC COLORS, STAMPEDE, 979 56 789 10 PAINTED METAL CANOPY - BENJAMIN MOORE, COLOR PREVIEW COLLECTION, JET BLACK, 2120-10 GARAGE DOOR - STERLING, FLUSH PANEL, SLATE GRAY EXTERIOR LIGHT FIXTURE - WAC LIGHTING, STAG, OUTDOOR LIGHTING WALL SCONCE, BLACK GLASS RAILING - COVER GLASS USA, CLEARLINE, FRAMELESS BASE SHOE SYTEM WITH NANORAIL TOP EDGE CAPPING DOUBLE-SIDED FIREPLACE - ACCUCRAFT FIREPLACE SYSTEMS, A-SS-5-10, SIGNATURE SERIES 31526 VALIDO ROAD -April 22, 2024 PROPOSED ELEVATIONS A-2.1 FYSB 20'-0"
17'-6" ABOVE
FRONT ELEVATION HEIGHT RYSB 20'-0"
21'-2" ABOVE
F.G. ELEVATION HEIGHT 221.60'

PROPERTY LINE

PROPERTY LINE
14'-8"

ABOVE NATURAL GRADE
15'-0"
ABOVE NATURAL GRADE ADDITIONAL BLDG. SETBACK MAX. BLDG. HEIGHT 17'-6" ABOVE
FRONT ELEVATION HEIGHT 221.60' RYSB 20'-0" FYSB 20'-0"
21'-8" ABOVE
F.G. ELEVATION HEIGHT
15'-0"

ABOVE NATURAL GRADE

PROPERTY LINE
PROPERTY LINE ADDITIONAL BLDG. SETBACK MAX. BLDG. HEIGHT 31526 VALIDO ROAD -April 22, 2024 ELEVATION BUILDING ENVELOPE A-2.2 484 of 821
485 of 821

PROPERTY LINE
PROPERTY LINE 239.10' 228.71'
21'-10" ABOVE
F.G. ELEVATION HEIGHT FOYER GREAT ROOMBEDROOM 2 DECK COURTYARD 217.67' F.F. 228.67' F.F. 228.50' F.F. 217.50' F.F. SECTION A 218.67' F.F. 218.00' F.G. 219.00' F.G. 221.60' 17'-6" ABOVE
FRONT ELEVATION HEIGHT 218.67' F.F.

PROPERTY LINE FYSB 20'-0"
17'-6" ABOVE
FRONT ELEVATION HEIGHT 221.60' 239.10' 218.00' F.G. 228.67' F.F. SECTION B FOYER DEN/OFFICE GARAGE SIDE ENTRY PRIMARY BEDROOM 3 LOFT BATH 31526 VALIDO ROAD -April 22, 2024 PROPOSED SECTIONS A-3.0 31526 VALIDO ROAD -April 22, 2024 3D VIEWS A-4.0 WEST ELEVATION EAST ELEVATION SOUTH ELEVATION NORTH ELEVATION BUILT-UP FLAT ROOF 1/4"/FT. SLOPE PARAPET @ 228.77' BUILT-UP FLAT ROOF 1/4"/FT. SLOPE BUILT-UP FLAT ROOF 1/4"/FT. SLOPE PARAPET @ 239.10' PARAPET @ 239.10' PARAPET @ 239.10' PARAPET @ 239.10'
PARAPET @ 239.10' 238.60' 238.60' 228.77' 228.77' 238.60' 238.60' 238.60' 228.27' SOLAR READY AREA PARAPET @ 239.10' SP#12 EL:239.10 FILL: SP#11 EL:239.10 FILL: SP#10 EL:239.10 FILL: SP#9 EL:239.10 FILL: SP#8 EL:239.10 FILL: SP#1 EL:239.10 FILL: SP#2 EL:239.10 FILL: SP#3 EL:239.10 FILL: SP#5 EL:239.10 FILL: SP#6 EL:239.10 FILL: SP#7 EL:239.10 FILL: SP#13 EL:239.10 FILL: SP#14 EL:239.10 FILL: SP#4 EL:239.10 FILL: 16'-2" 21'-8" SP# POLE NUMBER EL: MAXIMUM ELEVATION LEGEND:
31526 Valido Road
Laguna Beach, CA 12/10/2023 STORY POLE
STAKING PLAN 1/4" = 1'-0" SP#1 EL:239.10 SP#2 EL:239.10 SP#3 EL:239.10 SP#4 EL:239.10 SP#5 EL:239.10 SP#6 EL:239.10 SP#7 EL:239.10 SP#8 EL:239.10 SP#9 EL:239.10 SP#10 EL:239.10 SP#11 EL:239.10 SP#12 EL:239.10 SP#13 EL:239.10 SP#14 EL:239.10 A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE LIGHTING LEGEND SYMBOL DESCRIPTION MODEL NO. SCALE: 1/8" = 1'-0" 31526 VALIDO ROAD -January 16, 2024 NEW ASPHALT PAVING ENTRY COURT WITH STONE COLUMN WATER FEATURE SET IN COBBLE DECORATIVE COBBLE WALKWAY PRIVATE VIEW DECK, STONE PAVING OR PRECAST CONCRETE PAVERS LAWN FOR OUTDOOR EXERCISE(SEE PLANTING PLAN L-3) OUTDOOR LOUNGE AREA WITH DOUBLE-SIDED FIREPLACE AND CANTILEVERED WOOD DECK RETAINING/SEAT WALL, POURED IN PLACE CONCRETE WITH FIREPIT OUTDOOR DINING AREA WITH PREFAB BBQ COUNTER WALKABLE GROUND COVER(SEE PLANTING PLAN L-3) EXISTING TREE (BRACHYCHITON POPULNEUS) TO BE REMOVED FUEL MOD ZONE A FUEL MOD ZONE B SIGNIFICANT WATER BODY HARDSCAPE PLAN L-1 FUEL MOD ZONE B FUEL MOD ZONE C SIGNIFICANT WATER BODY SETBACK LINE VALIDO ROAD EXISTING TREE (PITTOSPORUM UNDULATUM) TO BE REMOVED EXISTING TREE (RHUS LANCEA) TO BE REMOVED EXISTING TREE (MORUS ALBA) TO BE REMOVED EXISITNG TREE (MYRICA CERIFERA) TO BE REMOVED ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE 31526 VALIDO ROAD -January 16, 2024SITE CHARACTERIZATION KEY MAP FUEL MODIFICATION NOTES A AC D PRIOR TO ISSUANCE OF UTILITY RELEASE ANNUAL INSPECTION AND MAINTENANCE c D F B B E F E SITE CHARACTERIZATION/NOTES L-2 SITE PHOTOS CYP CYP CYP A A A A A A A A A A A A A CS CS CS CS CS SS S S S CPPCPP CPP CPP MP MP MPMP MP MPMPMP MP MP MP CK CK CK CKCK BPBPBPBPBPBPBP BP BP BP PS PS PS PS PS PS PS PS PS PS PS PS PCNPCNPCN PCN PCNPCN PCNPCN PCN PCN CK CK S S CS CS S MPMP MP MP MP A A A A A A A A A A A A A A CK CK CPP CK MP SSS SS S S S SS CK CK S CYP PS MP PLPL PL PL LS LS LS LSLS LS LSLS LS LS LS BP CK CK H H H HHHH H HH H HH HH HHHHHHHH H HHHH H H PS PS PS PS PS PS PS S S S S S S S S LS LS LS LS WM WM WM WM WM WM WM PS RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP RP LSLSLS LSLSLSLSLSLSLSLSLSLS BP BP BP BP BPBP PH PH PH PH PH CK CKCK CK PS PS PS PT PT PT PT PT PT PT PT PTPT PT PT PT PT PTPT CKCKCKCKCKCKCKCKCKCKCKCKCKCKCKCKCKCKCKCKCKCK MP WM WM WM WM WM WM WM WM WM WM CK CK A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE SHRUB, VINE & GROUNDCOVER LEGEND SYMBOL BOTANICAL NAME "COMMON NAME" SIZE @ SPACING HT. X SPREAD SPECIMEN SHRUB LEGEND SYMBOL BOTANICAL NAME "COMMON NAME" SIZE @ SPACING HT. X SPREAD SLOPE PLANTING LEGEND 'MEADOW MIX' - SEED MIX FROM 'TREE OF LIFE NURSEY' SYMBOL BOTANICAL NAME "COMMON NAME" HT. X SPREAD TREE LEGEND SYMBOL BOTANICAL NAME "COMMON NAME" SIZE HT. X SPREAD 31526 VALIDO ROAD -January 16, 2024 AGA ATT 415 GAL. SCALE: 1/16" = 1'-0" ZONE MARKER, TYP. SEE DETAIL ABOVE PLANTING PLAN L-3 FUEL MOD ZONE A FUEL MOD ZONE B FUEL MOD ZONE B FUEL MOD ZONE C VALIDO ROAD NOT TO SCALE CHO TEC 215 GAL. AGA ATT 215 GAL. WES WYN 315 GAL. LEP PET 124" BOX MET EXC 124" BOX MET EXC 124" BOX A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE C 31526 VALIDO ROAD -January 16, 2024 SCALE: 1/16" = 1'-0" IRRIGATION LEGEND NEW PLANTING IRRIGATION SLOPE IRRIGATION IRRIGATION PLAN L-4 FUEL MOD ZONE A FUEL MOD ZONE B FUEL MOD ZONE B FUEL MOD ZONE C VALIDO ROAD A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks A-SITE-PROP magenta PHANTOM2 Property lines, survey benchmarks ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE ADJACENT RESIDENCE 31526 VALIDO ROAD -January 16, 2024 SCALE: 1/16" = 1'-0" HARDSCAPE OPEN SPACE LANDSCAPE OPEN SPACE PLAN L-5 VALIDO ROAD LANDSCAPE OPEN SPACE JOB NO. SHEET
1 39 Avenida Navarro
San Clemente, CA 92672
949.492.8586
www.toalengineering.com

CIVIL ENGINEERING

LAND SURVEYING

STORMWATER QUALITY
OF
PREPARED FOR:

APVD. DATE R E V I S I O N S BY DATE
APPD.:

DATE:

DWG. NO.

H. SCALE:

SURVEY DATE: V. SCALE:

CHD.:

DRN.:

HONGBIN PENG STAT E OF CA L I FORN I AL ICENSED LAND SURVEYO VIKTOR P.

R
MEUM
No. 8682
VIKTOR P. MEUM
P.L.S. 8682
DATE:
1/8"=1'
10-19-22-
11-10-22
MSFVM
2223611
TP-01POR. SW1/4, NE1/4. S5, T8S, R8W, SBBM, APN 056-062-25 31526 VALIDO ROAD, LAGUNA BEACH, CALIFORNIA

TOPOGRAPHIC AND BOUNDARY SURVEY
BENCHMARK NOTE:

OCSBM 3P-19-68
ELEV=120.364
NAVD88 DATUM, 2004 ADJ.

EASEMENT NOTE:

PER A PRELIMINARY TITLE REPORT PREPARED BY FIRST AMERICAN TITLE COMPANY, ORDER NO. O-SA-6859053 DATED JUNE 9, 2022, THERE ARE NO PLOTTABLE EASEMENTS IN SCHEDULE B. A PARCEL 2 OF THE PRELIMINARY TITLE REPORT IS A 25' WIDE EASEMENT FOR ROAD AND PUBLIC UTILITY PURPOSES. THE LEGAL DESCRIPTION APPEARS TO HAVE OMITTED SEVERAL COURSES. THE INTENDED EFFECT OF THE EASEMENT HAS BEEN PLOTTED HEREON.

SCALE: 1/8"=1'
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SECTION
GARAGE

SECTION
LEGEND
1 3 9 A v e n i d a N a v a r r o S a n C l e m e n t e , C A 9 2 6 7 2 9 4 9 . 4 9 2 . 8 5 8 6 w w w . t o a l e n g i n e e r i n g . c o m

C I V I L E N G I N E E R I N G

L A N D S U R V E Y I N G

S T O R M W A T E R Q U A L I T Y
BENCHMARK NOTE:

OCSBM 3P-19-68
ELEV=120.364
NAVD88 DATUM, 2004 ADJ.

EASEMENT NOTE:

PER A PRELIMINARY TITLE REPORT PREPARED BY FIRST AMERICAN TITLE COMPANY, ORDER NO. O-SA-6859053 DATED JUNE 9, 2022, THERE ARE NO PLOTTABLE EASEMENTS IN SCHEDULE B.

A PARCEL 2 OF THE PRELIMINARY TITLE REPORT IS A 25' WIDE EASEMENT FOR ROAD AND PUBLIC UTILITY PURPOSES. THE LEGAL DESCRIPTION APPEARS TO HAVE OMITTED SEVERAL COURSES. THE INTENDED EFFECT OF THE EASEMENT HAS BEEN PLOTTED HEREON.

DETAIL

ROLLED CURB
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These are photos of the flags that we see from our backyard and our bedroom. As you can see it totally blocks our view that we have seen for 34 years. I thought that I would add these to our letter.

Thank you
Diane Leemon
Yahoo Mail: Search, Organize, Conquer
On Sun, Jul 7, 2024 at 1:52 PM, STANTON LEEMON
<[email protected]> wrote:

From:

Dr. & Mrs. Stanton Leemon
31521 Toto Loma Lane
Laguna Beach
This is regarding property @31526 Valido
RD. Laguna Beach
We will be affected by this build in many ways.

1. If the driveway is lowered by 5ft will it affect the stability of our home as as projection is only 5 ft away from our property?

2. As the windows on this property will face our bedroom this will affect our privacy.

3. The lighting on the outside of this home will also affect us as it will shine in our bedroom at night.

4. The proposed fence which will be 8 to 12 feet high we think is in violation of building codes.

5. There were no Flags posted in the front of the property so we don't even know how close it will be to our home. This is a violation also.

6. The size of the new project is too big for the lot and is not conforming to our neighborhood. The lot is also right at a canyon. What are the requirements for this structure impacting the canyon?

7. The height of the structure poles indicate that the roof line of the proposed house will completely block our our view. The View that we have enjoyed for the last 34 years will be taken away from us and impact the value of our property. We moved here because of The View, the neighborhood and of course Laguna Beach.
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8.Is this property eligible for historic Landmark designation as it is 100 years old. We would hate to see this structure destroyed if it is historic.

Thank you so much for taking up these issues and to be listening to our stories. We apologize for the lateness of this letter as we just found out about doing this on July 4th.

Dr. & Mrs. Stanton Leemon
[email protected]
949-232-5568 cell
502
501 of 821
Site visit request please *important*
Lisa Boshnack <[email protected]>
Mon 6/17/2024 8:03 PM
To:Wank, Garrett CD <[email protected]>
1 attachments (3 MB)
SITE VISIT REQUEST BOSHNACK.pdf;
[NOTICE: This message originated outside of City of Laguna Beach -- DO NOT CLICK on links or open attachments unless you are sure the content is safe.]
Hello Garrett,
My husband Justin and I are requesting a site visit from the DRB members to our home at 31538 West St. in regards to our neighbors proposed project at 31526 Valido Rd.  This property is directly behind us.  We are extremely concerned with the second level, and are particularly concerned with the potential window placement as our bedroom looks directly into their proposed second level.  We have not seen the plans at all and we will be attending a meeting on Monday June 24th at 4pm with several other neighbors that have concerns.  It would have been nice to have seen the plans before, but they did not want to share the second story with the neighbors,only the first floor plans. I have attached a photo we took of the poles and flags which went up today.  This photo was taken from our bedroom window.

Unfortunately we are unable to attend the DRB meeting on 7/11 at 5pm as we are traveling to the East Coast to visit our family.  Our flight leaves on the 11th at 10:30am and we understand zoom is no longer being used due to security issues from zoom bombers.

We are home most days, please let us know when you and/or the DRB members can come out.  We feel them seeing our view in person standing in our bedroom would help them better understand our concerns.

Thanks,
Lisa Boshnack
7/2/24, 3:56 PM Mail - Wank, Garrett CD - Outlook
https://outlook.office365.com/mail/id/AAMkADRlOWRiYWFiLTQ4MmEtNDRhYy1iMTQwLWU2MzJlMjE0MzYwMgBGAAAAAAAUYnpZbakWQJ9nL5jS… 1/1 503
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Board of Adjustment/Design Review Board - 1 - July 11, 2024

MINUTES

BOARD OF ADJUSTMENT DESIGN REVIEW BOARD

REGULAR MEETING AND NOTICED HEARING
July 11, 2024
A regular noticed meeting of the Board of Adjustment/Design Review Board of the City of Laguna Beach, California, convened at 5:13 P.M. on July 11, 2024.

Meeting convened at a later time due to technical difficulties

Present: Jessica Gannon, Tom Gibbs, MJ Coveny, Louis Weil, Debbie Neev (Alternate)

Absent: Kristine Thalman
Staff Present: Wendy Jung, Daniel Latham, Kate Kazama, Garrett Wank, Shaveta Sharma, Ashley Rendon, Jane Abzug

1. CALLTO ORDER

2. PUBLIC COMMUNICATION - At this time, members of the public may address the Design Review Board regarding any items not on the agenda but within the subject matter jurisdiction of the Design Review Board. No action may be taken on off-agenda items unless authorized by law. Comments shall be limited to two (2) minutes each and fifteen (15) minutes for all comments, unless extended for good cause by the Design Review Board.

3. MODIFICATION OF AGENDA ORDER
None.

4. CONSENT CALENDAR

4.1. MINUTES APPROVED
Approval of the minutes of the Design Review Board/Board of Adjustment meeting on June 13, 2024.

Public Testimony: None.

On Consent, Ms. Neev made a motion, seconded by Ms. Coveny, to approve the minutes of the Design Review Board/Board of Adjustment meeting on June 13, 2024. The motion carried, 4-0. Mr. Weil abstained.

Motion DN Second MC Action APPROVED
Gannon Y Coveny Y Neev _Y_ Gibbs Y Weil _ABSTAIN_
Attachment 17
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Board of Adjustment/Design Review Board - 11 - July 11, 2024 Staff Presentation: Associate Planner, Garrett Wank, summarized the staff report.

Project Representative: Mr. Hutcherson gave his statement to support the proposed project.

Public Testimony: None.

Rebuttal: None.

Board Questions: None.

Board Comments: Ms. Coveny stated the project is a modest change that meets design review criteria such as privacy, view equity, the project is neighborhood compatible, and kept design integrity of the neighborhood. Ms. Coveny supported the project.

Mr. Gibbs provided assessments and found the project met neighborhood compatibility, and it did not impact views or privacy. Mr. Gibbs stated the project is acceptable, and it improves the neighborhood.

Ms. Neev concurred with her colleagues by agreeing that the project is neighborhood compatible and included the variance can be justified by the size and location of the project. Ms. Neev supported the project and variance.

Mr. Weil concurred with his colleagues and provided findings that support the project’s characteristic being consistent with neighboring homes. Mr. Weil supported the project.

Ms. Gannon concurred with her colleague’s comments. Ms. Gannon supported staff’s recommendation for approval and findings.

Mr. Weil made a motion, seconded by Ms. Gannon, to adopt resolution 24-0769 to approve Design Review 24-0769 and Variance 24-0770, and to adopt the categorical exemption pursuant to CEQA.

Ms. Abzug provided the suggested modifications.

Mr. Weil amended the motion to include the Deputy City Attorney’s recommendations.

The motion carried, 4-0. Mr. Weil abstained.

Motion LW Second JG Action APPROVED WITH CONDITIONS
Gannon Y Coveny Y Neev Y Gibbs Y Weil ABSTAINED

5.7. 31526 VALIDO ROAD (ZHOU), APN 056-062-25 CONTINUED TO SEPTEMBER 26, 2024
DESIGN REVIEW 24-0658, COASTAL DEVELOPMENT PERMIT 24-0657, AND CATEGORICAL EXEMPTION 505
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Board of Adjustment/Design Review Board - 12 - July 11, 2024 [Section 15303].

City Staff: Garrett Wank, Associate Planner (949) 464-6626 [email protected] Project Applicant: LCRA Architects, Architect (626) 449-9698 | [email protected] The applicant, LCRA Architects, requests Design Review 24-0658 and Coastal Development Permit 24-0657. The proposed project demolishing an existing singlefamily residence and construction of a new single-family residence, upper-level additions, elevated decks, grading, landscaping, tandem parking, and third covered parking space.

Disclosures: Ms. Coveny went to the site, met with Steve Kawaratani and left a message for the architect but did not receive a response. Ms. Coveny also met with neighbors: Mr. and Mrs. Leemon, the Boshnacks, the Chamberlains, and met with neighbors at 31532 West Street; Mr. Gibbs visited the site, met with Mr. Kawaratani, met with Sophia and Jeff Chamberlain, and met with Diana and Stan Leemon. Ms. Gannon was at the site visit with Ms. Coveny; Ms. Neev visited the site, met with the Chamberlains, met with Mr. and Mrs. Leemon, met with the Boshnacks, and met with Steve Kawaratani and with Mr.

Kawaratani’s assistance gained access to two neighbors homes and walked around the property; Mr. Weil spoke with Mr. Kawaratani, spoke with the applicant team over the phone, Mr. Weil walked the site and spoke with Diane Leemon over the phone.

Staff Presentation: Associate Planner, Garrett Wank, summarized the staff report.

Project Representative: Ms. Adele Chang presented the project.

Public Testimony: Mr. Kawaratani represented three adjacent neighbors. Mr. Kawaratani presented the neighbors’ concerns about the size of the home and privacy issues.

Mrs. Leemon presented her concerns of the project blocking views and privacy issues.

Mr. Chamberlain presented concerns of the project’s overall current plans.

Rebuttal: Ms. Chang addressed the concerns.

Board Questions: None.

Board Comments: Mr. Gibbs appreciated Ms. Chang’s comments. Mr. Gibbs addressed concerns of staking, mass and scale of the project, privacy issues, cooperating with neighbors to address concerns, suggested window locations for privacy, landscaping and provided articulation suggestions.

Ms. Coveny concurred with Mr. Gibbs’ comments. Ms. Coveny provided suggestions to the mass and scale of the home to help alleviate the neighbors‘ concerns and continued to provide suggestions to create privacy. Ms. Coveny provided suggestions for color consideration of the home.
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Board of Adjustment/Design Review Board - 13 - July 11, 2024 Ms. Neev believed in reducing the program overall and provided suggestions for privacy issues and concerns.

Mr. Weil appreciated Ms. Chang addressing the neighbors’ concerns. Mr. Weil provided suggestions for the design articulation that will help address view concerns pertaining to grading. Mr. Weil does not support tandem parking.

Ms. Gannon requested staking a specific area in order to visually see the proximity impact. Ms. Gannon suggested removal of the deck between bathrooms two and three.

Ms. Gannon provided feedback on the Juliet balcony.

Further discussion ensued pertaining to materials and articulation.

Mr. Weil made a motion, seconded by Ms. Neev, to continue Design Review 24-0658 and Coastal Development Permit 24-0657 to September 26, 2024. The motion carried unanimously, 5-0.

Motion LW Second DN Action CONTINUED TO SEPTEMBER 26, 2024 Gannon Y Coveny Y Neev Y Gibbs Y Weil Y

6. STAFF ANDBOARD REPORTS
None.

7. ADJOURNMENT
Adjournment at 7:35 p.m. to the regularly scheduled Design Review Board meeting on July 25, 2024, at 5:00 p.m.
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This transcript was exported on Oct 22, 2025 -
July 11 2024 (Item 5.7) (Completed 10/22/25)
Transcript by Rev.com

July 11, 2024, DRB Meeting, Item 5.7
Jessica Gannon:

Moving on, Item 5.7 located at 31526 Valido Road. This is for Design Review 24-0658 with a Coastal Development Permit 24-0657. Do we have the applicant team? Board ex parte? MJ Coveny:

I went to the site, walked it twice, met with Steve Kawaratani and also left a message for architect but never was reached.

Mr. Thomas Gibbs:

I went to the site, met with Steve Kawaratani. I also met with Sophia and Jeff Chamberlain and I met with Diana and Stan Leeman.

MJ Coveny:

And I just want to add to mine that I also met with several of the neighbors. Do I need to name them specifically? Hold on. There's a lot of them. Oh, heck. Where did my notes go? Oh, here we go. The homeowners at 31538 West Street, the Boshnacks. At 31532 West Street, it was the white house, I don't know who owns that and then 31532 Valido Street.

Jessica Gannon:

And I can read, while we're here, I was on the site visits with Ms. Coveny.

MJ Coveny:

And Jeff Chamberlain. The Leemons.

Jessica Gannon:

Leemons.

Debbie Neev:

Yes. I had site visit and met with the Chamberlains, met with Mr. and Mrs. Leeman and the Boshnacks and Steve Kawaratani and also Mr. Kawaratani let me into two other neighbor's homes, and we walked around the property.

Louis Weil:

I spoke with Steve Kawaratani and the applicant team over the phone. Walked the site and I spoke with, I'm sorry, I forgot to write it down. Diane Leeman, yes. I spoke with her on the phone and then I trespassed through a few different sites.

MJ Coveny:

Okay, great. Mr. Wank.

Garrett Wank:

Attachment 18
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This transcript was exported on Oct 22, 2025 -
July 11 2024 (Item 5.7) (Completed 10/22/25)
Transcript by Rev.com

Thank you. Item 5.7 is a request for design review and a coastal development permit at 31526 Valido Road located in the R1 zone. The site is currently developed with a single family dwelling and attached two car garage. Design review is required for a new single family residence, elevated decks, grading, landscaping, tandem parking, and a third covered parking space. The applicant is proposing to demolish an existing 1,278 square foot single family residence, construct a new 4,002 square foot single family residence with 461 square feet of elevated decks, grading, landscaping, tandem parking, and a third covered parking space. Staff has received neighbor concerns regarding the size of the structure, neighborhood compatibility, privacy, and view equity. The Board should consider whether these impacts affect the project's ability to meet the design view criteria. That will conclude my staff summary and I'm available for any questions.

MJ Coveny:

Board, do you have questions of staff? All right. The public hearing is now open.

Adele Chang:

Hello commissioners and Chair Gannon. My name is Adele Chang. I'm with LCRA Architects, the architect for the project. My office is up in Pasadena and our client lives in San Marino right next door and they had hoped that this would be a summer home for their family to escape the heat up in the San Gabriel Valley. They love this lot and it is a flag lot surrounded by five houses and all of those houses are twostory homes, a variety of styles, they're a mix of styles. So, the client wanted a more contemporary looking home and that's what we designed for them. We also designed a house that would fit her family's needs. This is our first project in Laguna Beach, so I'm here to learn. We did contact the neighbors and held a neighbor meeting. I've had a Zoom meeting with the Chamberlains and their architect as well as having met them on the site.

We have been in conversation with the owner of the easement, the access easement, to make sure we understand what he wants and doesn't want on that access driveway because the land belongs to him.

I've been in email conversation, exchanged a few emails with the owners of 31538. So, I've heard a number of neighbor concerns and I'm here to also listen to any comments and input that you have. After hearing the neighbor's comments, we have some thoughts and ideas on how to address them, including rotating the home, making the second floor more compact to allow for views from the upper neighbor.

And I think the rotation of the home will provide more privacy for the downhill neighbors. But I do want to mention that the current house, and if you were to stand in the backyard of the current house, which is pretty rundown by the way, already looks into the backyard of 31532. There's really no avoiding it because it's downhill and the other uphill neighbors can also look into their backyard.

That was brought up as a concern, but I just wanted to make that point. Otherwise, I'm here to answer questions and listen to your comments. Oh, one thing I did want to bring up is that in an effort to create something that is lower, we are proposing to grade the site down. It varies depending on where you are on the site from around eight feet close to the uphill side down to meet the grade at the lowest point of the site, not the entire site, but the lowest point of the pad.

Also by doing that, we are lowering and I heard that from staff that there was some question about the staking, the story post, and that's because it's based on the final elevation and the ground plane would be several feet below because we're ramping down or sloping down further into the site just so that we're tucked in more. Maybe one last thing is that we are not asking for any variances. We worked with staff extensively and Garrett can verify that. At one time we were having weekly Zoom meetings with him and so we did not want to deviate from the zoning ordinance. Was that the beep to stop? 509
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This transcript was exported on Oct 22, 2025 -
July 11 2024 (Item 5.7) (Completed 10/22/25)
Transcript by Rev.com

Jessica Gannon:

Yes.

Adele Chang:

Okay. I made it.

Jessica Gannon:

Was that or 30 seconds? Yep, 30 seconds.

Adele Chang:

That's it, that's all I have to say, I tried to be quick.

Jessica Gannon:

Okay, so then we are moving on to public commentary. Any member from the public wish to speak on this project? Mr. Kawaratani?
Steve Kawaratani:

Ms. Gannon, can you queue me up please, Garrett? My name is Steve Kawaratani and I do represent three adjacent neighbors. Before I start with my comments, welcome to Laguna Adele. You'll certainly learn a lot tonight.

The existing home is 1,276 square feet and the neighborhood average is 2,283 square feet. This project is being proposed at 4,002. We believe that it's too large. However, as the architect stated, it's going to be a two-story home, it would be unfair otherwise. I believe that if the architect would consider reducing the house to less than 3,600 square feet, we would lose that tandem parking condition and that area could be used for program. Maintaining the existing site orientation as the architect stated and adding the second story and the considerable glazing and deck is problematic to both my clients. I believe that the project does need to be rotated, the project lowered. I heard some good things that Adele mentioned and even pulled back from the rear would be very helpful. And of course redesigning the decks and the glazing and perhaps even taller hedging as Tom and Debbie brought up. If the hedge was allowed to go up, that would probably provide more ample protection. Next slide please.

So, that is the view impact from the Bernardi residence and I'm glad Adele's here to see how it's towering over their project. Next slide please. And this is the project directly behind. Currently, as designed, the house will have a great view into my client's master bedroom, so we're going to have to reorient the house. I think that'd be very helpful, very encouraged by what the project architect has said. And in closing, Adele Dave Whitaker who lives at 31532, has said he's willing to listen to you to perhaps lower the driveway, which would help if you're grading. Thank you very much Board.

Jessica Gannon:

Thank you Steve. Anyone else? Mrs, is it Leemon?
Mrs. Leemon:

Yes, Leemon.

Jessica Gannon:
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Yes. Leemon.

Mrs. Leemon:

It's like lemon with another E because we're sweeter.

Jessica Gannon:

I love...

Mrs. Leemon:

Thank you all so much for taking the time to make me feel better because I have lived in, I'm starting to speak tonight about our house at 31521 Toto Loma Ln. Our view equity will be taken away by the current plans for the new build at 31526 Valido Road. As you can see by the photos that I have previously sent you and on the visit to our home, that these views will be blocked anywhere between 50% to a 100% depending upon where you are on our property. Please consider that we have had these views for 34 years and moved to Laguna because we love it, because of the neighborhood and because of the view. I also would like to mention our privacy too because of the height of the house, their lights will be shining directly into our bedroom and they will also be able to see us. So, thank you so much for all the work that you've done.

Jessica Gannon:

Thank you Mrs. Leemon. Next speaker. Mr. Chamberlain, right? Mr. Chamberlain:

Yes, thank you.

Jessica Gannon:

Okay.

Mr. Chamberlain:

Thanks for the time. I'm just going to reread some of the stuff that I've already sent to you and I'll be as quick as I can. My name is Jeff Chamberlain and I live at 31551 Toto Loma with my wife Sophie and our two kids. We are directly next door to the proposed new home at 31526 Valido Road. While we welcome our new neighbors to the neighborhood, we would also like to express the following concerns with their current plans that don't yet seem to meet the criteria of design review guidelines. Some of them we've covered in our original letter to you and others in our personal meetings at our house, thanks for coming by yesterday by the way, but I'd like to repeat them here so that they are put on record. One, overall the height partially blocks portions of our view from several locations.

Their covered upper floor master bedroom deck particularly blocks our view from multiple points of our house including the living room, den and bedrooms. This roof over the upper deck seems unnecessary and could easily be removed without any change to the overall design. Two, the house has not been staked properly. They currently outline only the upper floor and their plans show that the first floor extends even closer to our house. Without proper and complete staking, it's impossible to understand the true impact of the designs mass and scale. Three, there is a lack of design articulation to the project overall. For example, there is one consistent roof parapet elevation all around the whole house. They seem to have filled the buildable envelope with the house rather than plan and accommodate views 511
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over the house. Four, the overall massing of the house seems inconsistent with our understanding of the design review guidelines.

In particular, neighborhood compatibility rather than feeling like a well articulated single-family home, it appears similar to a multifamily apartment block. There is simply nothing like this in the immediate surroundings. Five, there are two windows facing our home which will impact our privacy due to their location and proximity to our house and outdoor living areas. These windows are for the downstairs bathroom and the upstairs walk-in closet. Both are close to and immediately opposite our living room windows, our kids' bedroom windows, and our main outdoor living area. Our home will be impacted by the adjacency of these spaces.

Bathrooms and dressing areas are intimate places of a home and I'm sure that discretion with those areas would serve us both well. Six, the plans do not indicate where the air conditioning condensers will be located. We would like for them to not be close to our property, particularly our main outdoor living area, living room and children's bedrooms. Seven, landscaping is an important tool in good neighbor design. We don't think they've adequately addressed that yet in terms of side yard screening. Overall we're looking forward to meeting our new neighbors. I know it might not sound like it, but we are, but we ask Design Review Board to take into consideration our concerns. Thank you.

Jessica Gannon:

Thank you. Anybody else? Anders, you've been sitting back there a long time. You're not going to speak.

Anders:

I'm just chilling tonight.

Jessica Gannon:

All right.

Anders:

I'm here for moral support.

Jessica Gannon:

I love it.

Anders:

You designed the one that's under construction right there, right? Jessica Gannon:

Yes. He's representing Mr. Chamberlain. And then Mrs. Chung, did you have something you wanted to say earlier? No? Okay. Anyone else from the public like to speak on this project? All right, you have three minutes for rebuttal.

Adele Chang:

I'll address the last comments first. Regarding the staking, we realized that when Anders actually pointed that out to us, and I think I went to the site and I measured, so if story poles were up, they would be two feet to 30 inches above current grade because that's how far we have dug down, 512
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especially on that side of the property. So anyway, it would be below the height of their railing, of their rear deck, of the Chamberlain's rear deck. In terms of the windows that face their property, we're very happy to turn those into frosted glass, obscure glass windows. One is or maybe move the bathroom window. We just didn't want to have a blank wall, then the building would feel not articulated. In fact, the building has a lot of ins and outs.

If the Whitakers are willing to allow us to grade down a driveway approach slightly, then we would be able to start to have variations in parapet heights. We would be able to start to do that and I'm so happy to hear that he's willing to talk because he wasn't willing to allow us to do anything on the easement originally, besides to put up a six-inch curb to keep the driveway clean from the planting areas, that was all we were allowed to do. So I'm glad he's willing to listen to that. That may allow us to push the building down a little bit more.

And in terms of AC, I already talked with Garrett about where we proposed to put them and in the next round we'll go ahead and locate them. In terms of house size, we are the largest property in the area and we are within what's allowable in the code. Garrett told me that he would do a verification of neighboring sizes, so that would help us decide what to do. Am I forgetting? View equity, yes, we do plan on shrinking the second floor and adding frosted glass windows wherever we think is going to impact anyone's privacy.

Jessica Gannon:

Thank you.

Adele Chang:

Oh, one more thing.

Jessica Gannon:

Yes.

Adele Chang:

A hedge was planted last year and I think it needs to be allowed to grow, that will also help.

Jessica Gannon:

Okay, can you identify that plant?
Adele Chang:

The hedge? I believe your slides.

Jessica Gannon:

Is it in the plans?
Adele Chang:

The photos this gentleman took also show the beginning of that hedge.

Jessica Gannon:

Okay. Oh yes, I recall.
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Adele Chang:

Yeah, it should be allowed to grow. Once it does, I think it will also help the privacy issue.

Jessica Gannon:

Great. So Board. Any questions for the applicant? No questions? All right, so that officially closes out the public communication. Comments Mr. Gibbs, would you like to lead off? Mr. Thomas Gibbs:

Sure. First of all, I appreciate your comments tonight because you're putting a house in between five homes that are all closely impacted by your project and this goes to early neighbor communications.

Doing a lot of this thing to accommodate them, and your willingness to do that is really important to Laguna Beach. I know you're new here, but it's really important to DRB, it's design review, it's really important to the neighbors and the fact that you're willing to do that gives me a lot of confidence that the next round is going to be supported by neighbors rather than opposed. And I think you understand the concerns and from what I've heard, but let me go through my thoughts on the concerns.

First staking's really important and it's important to lay out the staking so that it matches the footprint of the building, both the first floor, second floor for view impacts and also privacy concerns so they can match up the 3D modeling that you've done to the staking so they can see where the windows are going to be, where the decks are going to be. Second, the mass and scale. I would need to be convinced that the, well first of all, I think you're entitled to a second-story home. The square footage, I need to see more data. It's not really, I think it's beyond the scope of this one, but it could be very important in the next one. So, it'd be important to potentially work with Mr. Kawaratani about square footages and see, you don't have to agree with him, but just to get an idea of what the data that we will look at in the next round. Again, I don't have a problem with the second story for this project. It's certainly neighborhood compatible.

With respect to privacy. The fact that you're willing to reorient the building to go out toward the canyon and toward the... In fact I think you'll have a better ocean view that way and better canyon view that way is important. At the same time, keep in mind that anytime you put a second story in particularly where it's been a one story and you're looking into people's backyards, it's important to think in terms of orientation, to minimize, there's going to be some impacts neighbors, you're going to have some impacts with respect to privacy issues. But the extent you can minimize them in your design, which it sounds like you're willing to do, and I think it's in everybody's interest to lower this building. And so whoever owns that easement needs to be more, not needs to, if the neighbors collectively could get that person to be more cooperative, and it doesn't sound like he has been, it doesn't have to be, there's no legal requirement, but that would solve a lot of people's problems and concerns both up and down from your project.

So, it sounds to me like private... And particularly the fact that you're going to make windows opaque that look into people's property, that's important too. Also, window location. I think in working with the neighbors and when you are able to get your building reoriented, I think you can solve all of those with these neighbors. I think their neighbors sounded me to be pretty reasonable. Also, in connection with privacy, landscaping could be a useful tool and I think in the next round focus more on landscaping, let's see if we can get this project approved the next round.

Articulation is my last comment. I think it does look like a duplex in some aspects or multifamily. I think a little bit more articulation. I think you can have that with respect to when you do some shrinkage with the second story to make it and use of articulation within the elevations, particularly elevations facing 514
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the neighbors in the front and the back. I think it used a little bit more, I think it's a pretty attractive modern building, but I think, you know the tools to make it a little bit more attractive because again, they're going to be looking at it. Those are my comments.

Jessica Gannon:

Great. Thank you Mr. Gibbs. Mrs. Coveny.

MJ Coveny:

May I go board?
Jessica Gannon:

You have the floor.

MJ Coveny:

Thank you Chair, thank you Chair. Thank you very much for being here. I had many ditto the notes here that Tom just gave. As far as the size of the building on this lot, I believe it's a 14,000 plus square foot lot. Now I know that must be the slope down and some of it's not completely buildable, but when you look at it overlaid with the old building, it doesn't feel like you're expanding that much over. But it would be great as we all work together here in order to alleviate some of the neighbor's concerns and still provide what's required for the homeowner, if you can scale that down a bit. The couple things I noticed on the plan specifically your renders here, let's see, the left elevation here, which I believe faces the 31538 West Street quite a bit. You have a bedroom off of an existing, excuse me, a deck off an existing bedroom. That deck is viewable. I got my East and Souths and Norths kind of confused on this sort of flag lot.

Adele Chang:

Yeah, because it's at an angle.

MJ Coveny:

Yeah, so basically I feel like, it is a suggestion you do what your next steps are, but it feels a little excessive from a privacy perspective if that could be a Juliet deck or if it could just become part of the program of the house, it's obviously would give you more square footage and would be enhancing that space and it would provide privacy to the neighbors. Also, the large wraparound deck, the majority of it wraps on the canyon side, which is awesome. The portion that if you're choosing to re-articulate seems like that would really relieve some of the privacy issues there for that wraparound deck that faces the...

Adele Chang:

More or less north.

MJ Coveny:

Right. Okay, thank you.

Adele Chang:

More or less.
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MJ Coveny:

And then the one area, the side of that, that would look over at the West Street homes, if there was a way to trellis that or something to make it not so straight in to that, rather than have to reduce the deck in any way. It feels like if you can just keep your L but block that one side might be a good option there.

The other Juliet deck off the other bedroom doesn't seem... Because it gets in a position, especially when you allow some of these hedgings to grow. You have a corner window in one of the rooms. As long as that's not creating, again, the hedging I think might protect the other home from that being a privacy issue. But that was something I noticed as well. And overall mass and scale, if I'm hoping again to Tom's point that the neighbor will work for the neighborhood.

I mean something's going to be built here. This is part of the empty lot syndrome. Even though there's an old home there, it's basically been an empty lot forever. So, when you try to drop something in it, it's overwhelming to the neighborhood. All of a sudden it's just becomes this thing. And so, dropping it down a little bit would relieve the mass and scale. I think your articulation's okay, in my opinion. Fixing the windows to glare and put them, glaze them or I can't think of the term when you fog it so the bathroom doesn't see out, the light isn't quite as strong on that one side.

The overall materials on the house, I don't think we're really allowed to comment, but a suggestion that if you would like to consider is when you do something in a white as opposed to more of an earth tone.

If you use more textural materials, it doesn't feel so antiseptic and big. If you can look at considering new materials on that, I think Mr. Chamberlain's home might have some good colors that warm it into the environment organically because white, sort of like jeans, you prefer black ones because you look thinner, white ones, anything white just feels larger.

That I think is enough to get you going but, overall I think is a really good first step. I didn't really look at landscaping. I will tell you that that will be a big thing the next round. Height, maintenance, privacy, that's going to become a big deal and I'll look at that much more thoroughly next round as well as lighting. People love to light these white things up, watch that. You just need enough to let people get in the door and walk around, but it can't become Hollywood Hills, so you have to be really careful on how much lighting you add to that. And that's all my little suggestions, thank you.

Adele Chang:

So that tell me I need to bring the landscape architect here next time.

Jessica Gannon:

Thank you, Mrs. Coveny. Yeah. Okay, thank you. Mrs. Neev.

Debbie Neev:

Yes. Well, I think you guys hit on many of the same issues that I had and not only, well first of all I think your comment about rotating and moving closer to that canyon is going to make a big difference I think, because you're so impacting that side, the West Street side and looming really looming from Mr.

Kawaratani's presentation really looming over the one neighbor. So I think, because that wrap around deck, I do believe considering reducing your program overall is something that you should really consider and I think there are a lot of places that you can, because even though the livable areas, 4,000 square feet with your storage and your garage, you're over 5,000 square feet. So that's a lot of program.

And one trigger is you have 48% impervious surfaces, which is under 50% is the guideline, but you have a 14,000 square foot lot.
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So, that's a lot of program on that lot. So, if you're considering rotating it, and I think that'll move a lot of that looming wrap around deck away and pulling that program in that, that will help a lot. And I think not only that, my colleague picked up on that, the deck that's between bathroom two and bathroom three, but there's also another balcony that's I think off of bedroom three. So even if you rotate, I think that those two balcony deck areas will still become a privacy issue. We've talked a little bit about the hedge. Normally on your side setback and your backs in your side and your rear, you're limited to six feet technically for fencing and things like that. So I think when you do your detailed landscape plan, be sure that you notate the heights of those hedges or trees and adding landscape can go a long way to help with the privacy issues.

I think that as you work that into your plans, that that can help a lot and go a long way toward some privacy concerns. So take a hard look at that. And then lighting was mentioned, frosting of the windows was mentioned. I think your plate heights are not excessive. They're nine feet plate height. So I think if you can work with your neighbor, even though you have 1,800 cubic yards of export already, I think that because there's view issues and view equity issues, I think that if you can work with them and maybe pull it again closer to the canyon and away, take a look. Please go into the Leemon's house, they have just some peekaboo views and I think so it's very, very critical as far as, I appreciate the flat roof because it could be worse, but I think that if you can lower it more and maybe look at some of the articulation, that would help a lot. So I think that's it.

Jessica Gannon:

Okay. Thank you Mrs. Neev. Mr. Weil.

Louis Weil:

Lots of comments and I want to take a moment and appreciate our conversation that this is a starting point for you guys and you wanted to come get feedback from the community and from the Board. So, I think that's the right approach for where we're at today and I appreciate the willingness to take this further and really reach out to the neighbors as I think you have over the last couple of weeks. It might've been a little eye-opening, but I think there's a lot of positives that can come from this and really yield a really positive project for this.

With that said, where we're starting with. The access component, I really think you need to look at lowering that driveway approach.

Adele Chang:

Yeah, it's a steep uphill drive.

Louis Weil:

It's a steep uphill, make it a nice little entry, make it softer. It'll also help lower the pad and I think that'll solve a handful of issues. And if you can accomplish that, I know it can create some nuisance during construction that it's more grading and a few more trucks, but keep in mind that it's just a period of time that that happens and occurs. It's not the permanent structure that stays there forever. And so it is a balance for me that if we get the right fit, the grading's appropriate. From a design articulation, it's a little boxy.

I don't have a preference of architectural style, modern, cottage, whatever, but I do want to see, if we're going to go modern, it needs to be a good fit and it needs to be softer, it's got to have some shapes and it's got to have some careful angles to support those views and the balance of privacy in that. I think this 517
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one was more designed economically, box on box, and I think it'd be a lot clever, more creatively done, and I know your firm can do that. But use materials to help soften it and bring that modern element to life. Landscape they were touching on, definitely got to get the mins and maxes incorporated in there because there's quite a few view lines through these neighboring properties.

Windows, I can't even talk on these ones because I think re-articulating it, repositioning, it's better. I think going closer to the hillside and just leveraging the lot you have room. In that same regard, the tandem parking, I can't support that on this lot. You just have enough space, it's not a constraint. I think if you need the third car spot, you just need to creatively do it so it doesn't add mass in scale, but because it's off the street, I think there's room to play with it or it really has to come down below the 3,600 square feet.

Two stories. I know that was commented, two story structure can go on the site. I want to make that known, it can fit, we just need to get the other elements to play. I think the square footage and those kind of things, it can be balanced and achieved in a different way and I'm encouraged to see that. Lots of comments, I'm not going to go any deeper because most of them were covered, but I just wanted to clarify that grading component is a really good tool to solve some of this.

Does that make sense?
Adele Chang:

It does.

Louis Weil:

Okay.

Adele Chang:

I understand everything you're saying.

Louis Weil:

Good.

Jessica Gannon:

You got a lot thrown at you. The only comment I have is when you do the staking, when you come back and do the staking, can you please, I think at the Chamberlains there's a... The lower floor pops out very closely to their house.

Adele Chang:

Yeah.

Jessica Gannon:

Can you stake that lower piece so we can see the impact of that? Adele Chang:

Yeah. I already started getting a proposal from the staking company to come back out. What you'll see is little stakes two feet up from the ground, because we are grading the most at the back. 518
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Jessica Gannon:

Right. I just mostly want to see the proximity that it is to the Chamberlains so we might have you reduce that. I would take a look at maybe even so you don't have to come back for a third hearing, maybe take a look at reducing that portion that sticks out close to the Chamberlains because that's their outdoor living space.

Adele Chang:

Right.

Jessica Gannon:

Yeah. And then the other comment that I have, the deck that's between bathrooms two and bathroom three, just get rid of it entirely.

Adele Chang:

Sure.

Jessica Gannon:

The Juliet balcony off of bedroom three, I'm okay with it, especially if you rotate the property and then, instead of repeating other board members, I think that's it. You've got a lot. Do you have any clarification questions for us?
Adele Chang:

No, I think I understand it will be a redesign. I'll come back with something new. It'll be different, especially on the second floor.

Jessica Gannon:

And I recommend breaking up the massing with different materials.

Adele Chang:

Yeah, we started to do that by introducing a siding material to various parts of the building but without having the entire thing be siding. And then we do have, we are proposing a stone near the entrance, where you step down to the entry court after you go by the garage. We are introducing that but maybe some color blocking will help too and softer colors instead of white.

Louis Weil:

You're the designer, we're going to let you come back with your creativity.

Mr. Thomas Gibbs:

I think the... I'm sorry, go ahead.

Louis Weil:

Sorry. I think we're all in favor of a continuance. So, if there's no other further comments, maybe we suggest some dates for you of how far out you want to be for coming back. 519
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Adele Chang:

Well some of it is contingent on being able to get a hold of Mr. Whitaker. Do we have to have... But can I discuss with staff? I need to contact Mr. Whitaker about lowering the...

MJ Coveny:

Would Steve Kawaratani be the best connection for that Steve? Adele Chang:

Well, I've been talking to him, so I have his email and phone number I believe.

Louis Weil:

For the easement?
Adele Chang:

Yeah, yeah.

Louis Weil:

I think you'll be in much better communication. Exchange numbers with Steve afterwards and you'll get the right contact.

Adele Chang:

Okay.

Jessica Gannon:

Board member Gibbs [inaudible 00:38:48].

Mr. Thomas Gibbs:

I think the neighbors collectively may help you there. I just had one follow-on comment, materials are one thing, but one of my comment and Board member Weil was, it's a boxy look and I think reducing the second floor and adding some articulation in addition to materials to bring to life the mid-century modern style that you have is really important I think for this project, given its location.

Adele Chang:

Okay, I get it.

Jessica Gannon:

Mrs. Chang, Jung.

Louis Weil:

Shouldn't be more than two months, to come back?
Adele Chang:

It shouldn't be more than two months.
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Mr. Thomas Gibbs:

Okay, so maybe we propose a date in September?
Wendy Jung:

Yeah, we just need to make sure we factor in time for the resubmittal and then staff time to review the revised design and prepare a staff report. There are two meetings in September.

Mr. Thomas Gibbs:

I think giving more time than two months would be helpful. I think there's some work to be done, not only with the easement but working with the neighbors. And Kawaratani is a good person, he will work with you toward coming up with solutions, and I think with the other neighbors, they're all reasonable.

So, I'd give them the time to go through that process, maybe three or four months.

Jessica Gannon:

And I like to note that I'm going to be absent for the second meeting.

Louis Weil:

Doesn't matter.

Wendy Jung:

So are you thinking of September or October would be preferred? Adele Chang:

I'm sure our client would prefer it to be sooner rather than later. We can work quickly, but there are elements beyond my control.

Wendy Jung:

So, an option is that to avoid re-noticing of a project, you could continue to a project or continue to a date in September, either the first meeting or the second meeting, and then if that time they require additional information, they could request a continuance.

Mr. Thomas Gibbs:

So, the second meeting's on when?
Wendy Jung:

The second, sorry, September 12th or September 26th.

Mr. Thomas Gibbs:

So the 26th and then the application would need to be in by August 26th? Wendy Jung:

Well, we would prefer probably at least five weeks in advance so that we could... 521
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Mr. Thomas Gibbs:

So what's that date?
MJ Coveny:

In October, is there two meetings in October? Perhaps the first week of October would be? Wendy Jung:

October 10th and October 24th.

MJ Coveny:

Yeah, I would think that would give you time to work with the neighbors, get through the city and get back here.

Jessica Gannon:

Well why don't we let the applicant decide. Yeah. So you want the second meeting? Adele Chang:

September?
Jessica Gannon:

Yeah, in September. Oh, staff, you can't be ready by then for the second meeting in September? Wendy Jung:

Oh, we could, I just wanted to make sure that we provide the applicant team with enough time to submit so that our staff can prepare it for the upcoming.

Adele Chang:

So you need five weeks in advance, five weeks.

Wendy Jung:

September, one, two, three.

Adele Chang:

In advance of the hearing.

Wendy Jung:

August 29th? Is that what you said?
Speaker 15:

Did you say five weeks [inaudible 00:41:55] 22nd.

Wendy Jung:

Oh, 22nd. Sorry. Oh, August 22nd, submit by.
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Adele Chang:

August 22nd. Okay.

Mr. Louis Weil:

If you're not in by then you can request a continuance.

Adele Chang:

Right.

Mr. Louis Weil:

So what's the meeting...

Adele Chang:

Do I have? Okay. I'll talk to staff about how to request and so forth, okay.

Jessica Gannon:

The 26th? September 26th?
Adele Chang:

That's the target, yes.

Louis Weil:

Chair on item 5.7 at 31526 Valido Road, the Board would approve a continuance to September 26.

Jessica Gannon:

Second.

Wendy Jung:

Board member Coveny?
MJ Coveny:

Yes.

Wendy Jung:

Board member Gibbs?
Mr. Thomas Gibbs:

Yes.

Wendy Jung:

Board member Weil?
Louis Weil:
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Yes.

Wendy Jung:

Chair Pro Tem Neev?
Debbie Neev:

Yes.

Wendy Jung:

And chair Gannon?
Jessica Gannon:

Yes.

Wendy Jung:

Thank you.

Jessica Gannon:

Thank you.

Wendy Jung:

Motion passes, five zero with a continuance to September 26. Design Review Board [inaudible 00:42:59], thank you.

MJ Coveny:

And Garrett, can I interrupt... Just, I'm sorry, Chair, can I ask Garret a quick question? I need a phone number, I don't think we had the right phone number. I just want to make sure we have the right contact info.

Jessica Gannon:

What's your phone number Love?
Adele Chang:

Can I provide my card?
Jessica Gannon:

Yes. Okay. Jessica, get us out of this.

Wendy Jung:

Can we adjourn? [inaudible 00:43:26]. No?
Jessica Gannon:

Okay. That's an adjournment.
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MJ Coveny:

I second.

Jessica Gannon:
[inaudible 00:43:30] Until.

Mr. Thomas Gibbs:

What's that?
Jessica Gannon:

Joe, we're...
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633 West 5 th Street
Suite 830
Los Angeles, CA 90071
213.599.4300 phone
213.599.4301 fax
esassoc.com
memorandum
date January 27, 2026
to Mr. Chuanjio Zhou
cc Steve Kawaratani, Richard A. McDonald, Esq.
from Dr. Margarita Jerabek
subject Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA ESA was commissioned by the property owner of 31526 Valido Road to prepare a Historic Resource Technical Memorandum in response to the Appeal of Resolution 24-0658. The Egan residence, 31526 Valido Road, is a single-family,1-story dwelling (ca. 1909; 1928 addition) (Subject Property) in the South Laguna neighborhood of Laguna Beach. ESA concurs with the Galvin Preservation Associates (GPA) peer review that the Subject Property does not fully meet the eligibility requirements of either the California Register of Historical Resources (California Register) or the National Register of Historic Places (National Register), nor does it appear to qualify under the City of Laguna Beach’s current Historic Preservation Ordinance, and as such, the Subject Property does not meet the definition of a “historical resource” under the California Environmental Quality Act (CEQA). In addition, ESA found the existing conditions of the Subject Property to be poor and it may not be feasible to rehabilitate the existing residence for current residential use without substantial adverse impacts to the historic integrity of its character-defining features. However, given that the Egan residence and the associated farmstead is one of the earliest historic-era settlements in the area, ESA concurs with GPA’s acknowledgement that there may be some potential for local historical significance associated with early rural residential development in South Laguna.

Specifically, a new residential project is proposed that would demolish the existing residence and construct a new 2-story single-family residence (Proposed Project). ESA, therefore, recommends the Proposed Project be conditioned to include a Preservation Plan by a Qualified Preservation Consultant to protect the history of the Subject Property including: (1) preparation of a Historic American Building Survey (HABS) report to document the history and existing conditions of the subject property; (2) and, if feasible, commemoration of the property’s history by an historical marker at the trailhead of the Cityowned Valido Trail that is located within the historically associated homestead tract; (3) and, if feasible, relocation of the original ca. 1909 portion of the existing residence for interpretive purposes such as a house museum. If relocation would not be feasible, salvage of selected character-defining historic materials and their donation to an entity such as a historical society/museum would be appropriate. These are industry standard treatment measures that are used to preserve the significance of historical resources for the public benefit. The methods and results of our assessment are summarized below in greater detail.

RECEIVED 01/27/2026 PLANNING DIVISION

CITY OF LAGUNA BEACH
Attachment 21
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 2 Methods
ESA reviewed the Appeal of Resolution 24-0658 and associated documents including the previous historic resource assessments by Historic Resources Group (HRG) and Chronicle Heritage (CH), and the peer review by GPA. ESA reviewed available City building and planning documents, and Orange County Assessor Records for the subject property to verify the accuracy of the previous studies and learn in greater detail about the construction history of the subject property. ESA conducted online archival research to further verify the accuracy of the previous studies and learn more about the history and use of property, including Newspapers.com, Online Archive of California (OAC), historic aerial photographs and topographic maps. ESA’s principal architectural historian, Dr. Margarita Jerabek, conducted a site visit and survey to visually inspect and photographically document the exterior, interior and associated ancillary buildings and landscape of the subject property on October 29, 2025. Dr. Jerabek has over 15 years of experience conducting historic resource studies in Laguna Beach and Southern California and meets the Secretary of the Interior’s Professional Qualifications Standards in History and Architectural History (resume attached).

Regulatory Framework
Historical resources fall within the jurisdiction of the Federal, State, and Local designation programs.

Federal laws provide the framework for the identification and organization of historical resources, and in certain instances, protection. State and Local jurisdictions play active roles in the identification, documentation, and protection of such resources within their communities. The National Historic Preservation Act (NHPA) of 1966, as amended, and the California Public Resources Code (PRC), Section 5024.1, are the primary Federal and State laws and regulations governing the evaluation and significance of historical resources of national, state, regional, and local importance in Laguna Beach. The Laguna Beach Historic Preservation Ordinance (Laguna Beach Municipal Code 25.45), originally adopted in 1989, governs the criteria for determining eligibility for local historical resources. The City Council adopted a revised ordinance in August 2020, which updated Chapter 25.45 of the Laguna Beach Municipal Code. The Coast Commission approved the ordinance revisions February 10, 2022, and City Council approved a further revised, voluntary Historic Preservation Program, April 26, 2022. The Coastal Commission certified the voluntary program, July 13, 2022.1 National Register of Historic Places
The National Register was established by the NHPA as “an authoritative guide to be used by Federal, State, and Local governments, private groups and citizens to identify the Nation’s cultural resources and 1 City of Laguna Beach, “California Coastal Commission Approves City’s Historic Preservation Ordinance,” City of Laguna Beach News, 02/11/2022
(https://www.lagunabeachcity.net/Home/Components/News/News/357/13#:~:text=California%20Coastal%20Commission% 20Approves%20City's,before%20it%20can%20be%20implemented., accessed 12/9/2025); and Laguna Board of Realtors, “Historic Preservation Ordinance,” 2025 (https://www.lagunarealtors.org/governmentaffairs/historic-preservationordinance/#:~:text=City%20of%20Laguna%20Beach%20Historic,the%20revised%20Historic%20Preservation%20Ordinanc e., accessed 12/9/2025)
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 3 to indicate what properties should be considered for protection from destruction or impairment.”2 The National Register recognizes properties that are significant at the national, state, and/or local levels.

To be eligible for listing in the National Register, a resource must be significant in American history, architecture, archaeology, engineering, or culture. Four criteria for evaluation have been established to determine the significance of a resource. They include the following:

Criterion A. Associated with events that have made a significant contribution to the broad patterns of our history;
Criterion B. Associated with the lives of persons significant in our past; Criterion C. Embodies the distinctive characteristics of a type, period, or method of construction or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; Criterion D. Yields, or may be likely to yield, information important in prehistory or history.3 Districts, sites, buildings, structures, and objects that are 50 years old or older must meet one or more of the above criteria and retain integrity of location, design, setting, materials, workmanship, feeling, and association to be eligible for listing.

Within the concept of integrity, the National Register recognizes seven aspects or qualities that, in various combinations, define integrity: Location, Design, Setting, Materials, Workmanship, Feeling, and Association:

Location is the place where the historic property was constructed or the place where the historic event occurred. The relationship between the property and its location is often important to understanding why the property was created or why something happened. The actual location of a historic property, complemented by its setting, is particularly important in recapturing the sense of historic events and persons. Except in rare cases, the relationship between a property and its historic associations is destroyed if the property is moved.

Design is the combination of elements that create the form, plan, space, structure, and style of a property.

It results from conscious decisions made during the original conception and planning of a property (or its significant alteration) and applies to activities as diverse as community planning, engineering, architecture, and landscape architecture. Design includes such elements as organization of space, proportion, scale, technology, ornamentation, and materials. A property’s design reflects historic functions and technologies as well as aesthetics. It includes such considerations as the structural system; massing; arrangement of spaces; pattern of fenestration; textures and colors of surface materials; type, amount and style of ornamental detailing; and arrangement and type of plantings in a designed landscape. 2 36 CFR Section 60.2.
3 36 CFR § 60.4 – Criteria for evaluation. For evaluation guidelines see “Guidelines for Completing National Register Forms,” in National Register Bulletin 16, U.S. Department of Interior, National Park Service, September 30, 1986. This bulletin contains technical information on comprehensive planning, survey of cultural resources and registration in the NRHP.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 4 Setting is the physical environment of a historic property. Whereas location refers to the specific place where a property was built or an event occurred, setting refers to the character of the place in which the property played its historic role. It involves how, not just where, the property is situated and its relationship to surrounding features and open space.

Workmanship is the physical evidence of the crafts of a particular culture or people during any given period in history or prehistory. It is the evidence of artisans’ labor and skill in constructing or altering a building, structure, object, or site. Workmanship can apply to the property as a whole or to its individual components.

Materials are the physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property.

The choice and combination of materials reveal the preferences of those who created the property and indicate the availability of particular types of materials and technologies. A property must retain key exterior materials dating from the period of its historic significance.

Feeling is a property’s expression of the aesthetic or historic sense of a particular period of time. It results from the presence of physical features that, taken together, convey the property’s historic character.

Association is the direct link between an important historic event or person and a historic property. A property retains association if it is the place where the event or activity occurred and is sufficiently intact to convey that relationship to an observer.4
To retain historic integrity, a property will always possess most of the aspects described above.

Depending upon its significance, retention of specific aspects of integrity may be paramount for a property to convey its significance.5 Determining which of these aspects are most important to a particular property requires knowing why, where and when a property is significant.6 For properties that are considered significant under National Register Criteria A and B, National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation (National Register Bulletin 15) explains, “a property that is significant for its historic association is eligible if it retains the essential physical features that made up its character or appearance during the period of its association with the important event, historical pattern, or person(s).”7In assessing the integrity of properties that are considered significant under National Register Criterion C, National Register Bulletin 15 states, “a property important for illustrating a 4 National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, 44-45, https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf. 5 The National Register defines a property as an “area of land containing a single historic resource or a group of resources, and constituting a single entry in the National Register of Historic Places.” A “Historic Property” is defined as “any prehistoric or historic district, site, building, structure, or object at the time it attained historic significance.” Glossary of National Register Terms https://www.nps.gov/subjects/nationalregister/upload/NRB16A-Complete.pdf. 6 National Register Bulletin 15, p. 44.
7 “A property retains association if it is the place where the event or activity occurred and is sufficiently intact to convey that relationship to an observer. Like feeling, association requires the presence of physical features that convey a property’s historic character. Because feeling and association depend on individual perceptions, their retention alone is never sufficient to support eligibility of a property for the National Register.” Ibid, p. 46. 566
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 5 particular architectural style or construction technique must retain most of the physical features that constitute that style or technique.”8
Under the National Register, alterations to a structure do not necessarily disqualify a property from a potential listing. A property can be significant not only for the way it was originally constructed, but also for the way it was adapted at a later period, or for the way it illustrates changing tastes, attitudes, and uses over a period of time.9
California Register of Historical Resources
The State OHP, as an office of the California Department of Parks and Recreation (DPR), implements the policies of the NHPA on a statewide level.

The OHP also performs the duties as set forth in the PRC and maintains the Historical Resources Inventory (HRI) and the California Register. The State Historic Preservation Officer (SHPO) is an appointed official who implements historic preservation programs within the state’s jurisdictions.

Also implemented at the state level, the California Environmental Quality Act (CEQA) requires projects to identify any substantial adverse impacts which may affect the significance of identified historical resources.

The California Register was created by Assembly Bill 2881 which was signed into law on September 27, 1992. The California Register is “an authoritative listing and guide to be used by state and local agencies, private groups, and citizens in identifying the existing historical resources of the state and to indicate which resources deserve to be protected, to the extent prudent and feasible, from substantial adverse change.”10 The criteria for eligibility for the California Register are based upon National Register criteria.11
The California Register consists of resources that are listed automatically and those that must be nominated through an application and public hearing process. The California Register automatically includes the following:
• California properties listed on the National Register and those formally Determined Eligible for the National Register; 12
• California Registered Historical Landmarks from No. 770 onward; 8 “A property that has lost some historic materials or details can be eligible if it retains the majority of the features that illustrate its style in terms of the massing, spatial relationships, proportion, pattern of windows and doors, texture of materials, and ornamentation. The property is not eligible, however, if it retains some basic features conveying massing but has lost the majority of the features that once characterized its style.” Ibid. 9 National Register Bulletin 15, p. 19.
10 PRC Section 5024.1(a).
11 PRC Section 5024.1(b).
12 PRC Section 5024.1(d).
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 6 • Those California Points of Historical Interest (PHI) that have been evaluated by the OHP and have been recommended to the State Historical Commission for inclusion on the California Register.13 Other resources which may be nominated to the California Register include:
• Individual historical resources;
• Historical resources contributing to historic districts; • Historical resources identified as significant in historical resources surveys with significance ratings of Category 1 through 5;
• Historical resources designated or listed as local monuments, or designated under any local ordinance.
14 To be eligible for the California Register, a historical resource must be significant at the local, state, or national level, under one or more of the following four criteria:

1. Is associated with events that have made a significant contribution to the broad patterns of California's history and cultural heritage;

2. Is associated with the lives of persons important in our past;

3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

4. Has yielded, or may be likely to yield, information important in prehistory or history.

Additionally, a historical resource eligible for listing in the California Register must meet one or more of the criteria of significance described above and retain enough of its historic character or appearance to be recognizable as a historical resource and to convey the reasons for its significance. Historical resources that have been rehabilitated or restored may be evaluated for listing. Integrity is evaluated with regard to the retention of seven aspects of integrity similar to the National Register (location, design, setting, materials, workmanship, feeling, and association). Also like the National Register, it must be judged in context to the particular criteria under which a resource is proposed for eligibility. Alterations over time to a resource or historic changes in its use may themselves have historical, cultural, or architectural significance. It is possible that historical resources may not retain sufficient integrity to meet the criteria for listing in the National Register, but they may still be eligible for listing in the California Register. A resource that has lost its historic character or appearance may still have sufficient integrity for the California Register if it maintains the potential to yield significant scientific or historical information or specific data.15
13 PRC Section 5024.1(d).
14 PRC Section 5024.1(e)
15 Codified in California Code of Regulations, Title 14, Chapter 11.5, Section 4852(c) which can be accessed on the internet at http://ohp.parks.ca.gov
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 7 City of Laguna Beach Code of Ordinances Chapter 25.45 Historic Preservation16
Under Section 25.45.004 “Definitions” of the City’s Historic Preservation Ordinance a “Historic Resource” means a property or structure that
(1) is listed in the City’s historic register, (2) is listed in the California Register of Historical Resources, (3) has been officially determined to be eligible for the California Register of Historical Resources by the State Historical Resource Commission, (4) is listed in the National Register of Historic Places, (5) has been officially determined to be eligible for the National Register of Historic Places by the National Park Service, or (6) the City is mandated by law to treat as a historic resource based on substantial evidence in light of the whole record. Generally, a resource shall be considered to be “historically significant” if the resource meets the criteria for listing in the California Register of Historical Resources.

Under Section 25.45.004 “Definitions” of the City’s Historic Preservation Ordinance Historic integrity” means,
the ability of a property to convey its significance. Historic properties either retain integrity (that is convey their significance) or they do not. Within the concept of integrity, the National Register criteria recognizes seven aspects or qualities that, in various combinations, define integrity. The seven aspects are location, design, setting, materials, workmanship, feeling and association.

Under Section 25.45.004 “Definitions” of the City’s Historic Preservation Ordinance, “Character-defining features” include,
the overall shape of the building, its materials, craftsmanship, decorative details and features, as well as the various aspects of its site and environment. These features capture the historic character of a building.

Under Section 25.45.004 “Definitions” of the City’s Historic Preservation Ordinance, “Cultural landscape” means,
a geographic area, including both cultural and natural resources and the wildlife or domestic animas therein, associated with an historic event, activity, or person or exhibiting other cultural or aesthetic values.

Under Section 25.45.006 Historic Register designation, criteria and procedures for removal from register, subsection (A) “the purpose of the Laguna Beach historic register is to provide a means to preserve, protect and enhance historic resources within the community, including buildings, structures, sites, objects, districts and cultural or historic landscape features.” Under subsection (B), designation procedures include completion of proposed designation applications by property owners, review of 16 City of Laguna Beach, 2025-10-28, Code of Ordinances, Title 25 Zoning, Chapter 25-45 Historic Preservation (https://ecode360.com/42901400#42901401, accessed 12/9/2025). 569
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 8 applications by the Heritage Committee, and recordation of a written preservation agreement between the City and the property owner. If an owner applies for incentives (i.e. parking, permit and planning fees, building code deviations, commercial additions, setback flexibility, density bonuses, open space requirements, official recognition, priority processing, financial/Mills Act, bed and breakfast, nonconforming requirement relief), the recordation shall not occur until the owner’s incentive request has been acted upon. The agreement is then recorded with the County and will apply to subsequent owners.

Under Section 25.45.006 Historic Register designation, Subsection (C) Criteria for Historic Register Listing, a building, grouping of buildings, structure, site, object, or district shall be considered for designation by the Heritage Committee if it meets criteria (1) and also one or more of criteria (2) through (11):
(1) The owner of the property voluntarily agrees to the placement on the register; (2) It is listed on the National Register or the State Register; (3) It exemplifies the cultural, political, economic, social or historical heritage of the community; (4) It is identified with a person, events, cultural or site significant in local, state or national history; (5) It is representative of the work of a notable builder, designer, architect, or artist including those of local importance;
(6) It embodies distinguishing architectural characteristics of a style, type, period or method of construction that exemplify a particular architectural style or way of life important to the City; (7) It embodies elements that represent a significant structural, engineering, or architectural achievement or innovation;
(8) It has unique location, singular physical characteristic, or is an iconic visual feature or public view within the City;
(9) Is one of the remaining examples in the City, region, state or nation possessing distinguishing characteristics of architectural, cultural or historical importance; (10) Is an iconic landscape, garden, space or public viewpoint that is significant to the history and heritage of the City; or
(11) Has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California or the nation.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 9 Environmental Setting
Historic Context
City of Laguna Beach, South Laguna Community17
The City of Laguna Beach is unique in Southern California due to its dramatic topography. The art inspiring landscape includes steep coastal mountains, rolling hills of chaparral and coastal sage scrub, unique geological formations that plunge into the sea and over thirty individual coves and beaches along an eight and half mile stretch of coastline.

Early inhabitants of Laguna were drawn to the area for its abundance of natural resources and the warm relief of the coast. Native Americans frequented the coves of Laguna, where they made hooks of bone to catch fish, ate abalone and limpets, and fashioned shells for jewelry, knives, and dishes. Social camps developed with time and remnants have been found in the areas of Capistrano Bay and along the freshwater banks of Aliso and San Juan creeks.

Although the North Laguna area was originally part of the San Joaquin Rancho, downtown Laguna and South Laguna were never part of a Spanish or Mexican land grant. This meant that these areas remained available for government sponsored homesteading. As a follow-up to the Homestead Act of 1862, the Timber Culture Act of 1873 was designed to encourage migration to the “Golden West” by granting 160 acres of land to anyone planting 40 acres of trees (reduced to 10 acres in 1878). Families began to arrive and stake out their 160‐acre claims and plant the requisite trees, which in Laguna meant the Australian eucalyptus. The groves planted in the 1880s helped form the character of Laguna Beach and added much needed shade, although as lumber they were virtually useless.

In 1871, Eugene Salter, the first American settler of South Laguna, claimed part of Aliso Canyon. He soon left and his 152 acres along with a one room shack that he built were claimed by George and Sarah Thurston. George Thurston raised vegetables and melons and sold them in Los Angeles, which was then a five-day trip by wagon. The family name is memorialized throughout Laguna by the naming of various sites including the Thurston Intermediate School, Thurston Street, and Sarah Thurston Park in Laguna Canyon.

The Brooks brothers, William and Nathanial, arrived in town and settled in 1876. Both are commonly referred to as the “father of Laguna” depending on which source is referenced. They are considered the official first homesteaders, the first pioneers to stay longer than one summer. William H. Brooks came from Downey on a hunting trip, following the old Indian trail through Laguna Canyon. Later William filed on 169.24 acres of land at Arch Beach (now Diamond Street) and laid out a subdivision. William’s brother Nathanial brought water from Bluebird Canyon through a series of pipes and tunnels to Arch Beach. The Arch Beach lot would be later sold to Hubbard Goff 17 Excerpted from Karen Turnbull’s “Laguna Beach and South Laguna” in A Hundred Years of Yesterdays: A Centennial History of the People of Orange County and their Communities, Santa Ana, CA: the Orange County Centennial, Inc., 1988; from Jan Ostashay’s Halliburton House Indirect Impacts Assessment, prepared for the City of Laguna Beach, 2013. 571
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 10 (remembered in Goff Street and Goff Island) who opened the first hostelry in Laguna, the Arch Beach Hotel, in 1886.

By 1888, there were approximately 15 permanent families living in Laguna Beach. By then, the area had gained a reputation as a seaside resort ideal for summer camping and vacationing. A year later a second hotel was built in Laguna by Henry Goff and purchased by Joseph Yoch. Yoch also bought the defunct Arch Beach Hotel and had it moved in sections into town. The two hotels were joined, creating one large hostelry.

This hotel was condemned in 1928, and the present Hotel Laguna opened the following year on the same site.

During the southern California real estate boom of the 1880s, Arch Beach was a separate community. It was granted a post office in 1889, two years before Laguna had one. From May 15, 1891, to September 17, 1904, Laguna Beach was called “Lagona,” a corporation of the Spanish word for lagoon. The first postmasters were Hub Goff at Arch Beach and Joseph Yoch in Laguna.

In South Laguna, a few keys families were homesteaders raising beans and melons.

Several times South Laguna came close to commercialism. In 1889, the Santa Fe railroad purchased Goff’s Island (in later years referred to as Treasure Island and now the Montage Resort and Spa) and planned a depot and resort. When the rail tracks were set inland instead, those plans for the depot and resort failed. At that time, the depression of the 1890s saved South Laguna from an urbanized future.

The first artist to arrive in Laguna was Norman St. Clair, who in 1903 reached the town by train from Los Angeles and stagecoach from El Toro. He made numerous sketches of the surf, hillsides, and lagoons. His fellow plein air artists in San Francisco were so impressed with his work and his praise of the weather in Laguna that they began to move to the area and a tradition was established. As news of this picturesque village spread, the artists came in droves. Many of the artists banded together and held their first exhibit in 1918. This showing was the beginning of the Laguna Beach Art Association and the present Laguna Beach Art Museum.

The Coast Royal area of South Laguna was first subdivided by Horace J. Pullen in 1906.

However, his partner, Blanche Dolph, was not consulted on the subdivision and she filed suit to stop the sale. Los Angeles newspapers branded it a swindle and the subdivision died.18 In 1924, the Skidmore Brothers of Laguna Beach purchased the subdivision and began to develop it. Coast Royal is important in local history as the beginning of the southern expansion of Laguna Beach and as the first development in South Laguna. It preceded Three Arch Bay and the rest of South Laguna by two or three years, and the hillside roads were graded before the completion of the (Pacific) Coast Highway.19 The opening of Coast Highway in 1926 was a major stimulant for growth in both Laguna Beach and South Laguna. Opening of the highway along the coast brought in not only tourists and film celebrities but more permanent residents. With a population of 1,900 Laguna Beach was incorporated as a city on June 29, 1927.

Since its incorporation, the city continued to grow and expand. With the increase of summer visitors, the demand for permanent residents to provide services for vacationers 18 Karen Turnbull, "Historic Resources Inventory DPR 523 Series: Coast Royal," prepared by Environmental Coalition, 1981,

2. 19 Ibid.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 11 also increased. More and more beach cottages began to be built, and those who had previously been seasonal residents made Laguna Beach their permanent home. All manner and style of housing began to be erected in what was almost an “anything goes” atmosphere with very lax building requirements.

Almost every house built in Laguna Beach prior to 1927 had its roots in the Craftsman tradition. Unlike most cities whose older building stock concentrated in one area near the city center, people who came to Laguna Beach had a preference for the seclusion offered by the wide-open spaces. The influence of artists and movie people of the 1920s led to individualized, unique architecture, which formed good replicas of styles popular in other continents. Thus, Laguna Beach architecture illustrates the personality that results from one‐of‐a‐kind interpretations of traditional and revival styles, as well as strong European influences in the desire to emphasize the village quality.

Similar to Laguna Beach, South Laguna also had structures built in a variety of architectural styles during roughly the same time period (1920‐1940). The development of Tract 849 (South Laguna Village) and Three Arch Palisades (Three Arch Bay) was shepherded by Edward G. Chatham; his son, Lesley G. Chatham; and his brother‐in‐law, Lewis Lasley. After the opening of the Coast Highway lots were actively promoted for sale in both South Laguna Village and Three Arch Bay. Richard Halliburton, world renowned adventurer and writer, came to Laguna in the early 1930s. So enchanted with the charming community, natural landscape, and commanding views he had his first and only house custom built for him in South Laguna in 1937. Of concrete construction set upon the summit of a ridge adjacent to Aliso Creek below the concrete monolith was designed in the International Style by architect William Alexander Levy.

This early and unusual modernistic structure further expanded the architectural portfolio of the community.

Since South Laguna was considered an unincorporated area of the County of Orange the South Laguna Civic Association was established in 1946 and represented the area’s interests, primarily in relation to community planning. Early subdivisions were not required to provide sewer and water services or paved roads. In the 1930s and 1940s, efforts were made to provide the most basic of services.

Infilled development occurred in the post‐World War II years throughout Laguna. The majority of lower Laguna Beach below High Drive on the north and Temple Hills Drive on the south now contains a mix of old and new housing with architectural styles that reflect the varying eras in which they were built. Development and subdivision activity during the late 1950s and mid‐1960s was primarily concentrated on the City’s ridgelines, hilltops and hillsides, leaving less accessible hillsides, ridgelines, and canyon bottoms vacant. In 1987, South Laguna, the Old Top of the World area, and Allview Terrace were annexed to the City of Laguna Beach. A large segment of Laguna Canyon was annexed in 1989.

The fact that the railroad never had tracks into Laguna Beach and that, still today, only two roads lead in and out of the city, has caused Laguna to remain a somewhat isolated and self‐contained village. The scale and character of housing styles and overall density of the neighborhoods follows today a precedent set by those who came to Laguna Beach in the 1920s. Today, Laguna contains a myriad of residential and commercial building styles all with the mark of charm, uniqueness, and individuality that has been popular in the city through the decades. The individuality of the existing older homes resulted from the general lack of large tract development. The result is a very diverse collection of architecture without large concentrations of one particular style found in other south Orange County communities.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 12 Identification of Historical Resources
The Subject Property was not identified during the 1980-81 Laguna Beach Historic Resources Survey, presumably because it is set back from the road and was not visible to surveyors from the public right of way during the survey. It was not included in the Historic Resources Inventory in 1982, 20 nor is it
currently listed in the Laguna Beach Historic Register.21 Since the Subject Property has not been identified in previous surveys nor individually evaluated for eligibility to the state or national register, it therefore has not been listed in the Office of Historic Preservation’s (OHP) inventory of nonarchaeological resources, the Built Environment Resource Directory (BERD).22 The Subject Property was sold June 6, 2024,23 to a new owner who proposes to construct a new two-story single-family home on the Subject Property. As a part of the project review process, the City requested a Historic Assessment Report be prepared for the subject property to determine if it is considered a historic resource pursuant to the California Environmental Quality Act (CEQA). Several recent studies have been prepared, summarized below.

Recent Studies

1. Historic Resources Group. Historic Resources Assessment, 31526 Valido Road, Laguna Beach.

November 22, 2024. Prepared for City of Laguna Beach.

The HRG report found the Subject Property eligible for the National Register under Criterion A at the local level of significance, and the California Register under Criterion 1, for its association with the Homestead Act of 1862. The HRG report developed Turnbull’s history of South Laguna further, provided background on how the Homestead Act of 1862 and the later Timber-Culture Act were implemented in South Laguna, and documented the construction and occupancy history of the Subject Property in detail.

The Subject Property was part of a 40-acre homestead claim in 1910 by William Frederick Egan (b. 1862, d. 1930). His uncle, James M. Shrewsbury, claimed 160 acres of land in 1911 northeast of Egan’s land.

Together, Egan and Shrewsbury established homesteads and farmed vegetables including string beans, squash, lima beans and melons that were shipped to market in Los Angeles and San Francisco. Egan built a one-room cabin (ca. 1909) which was expanded into a two-bedroom cottage (1928). In 1920, the Egans built a new home in Spadra where they had family ties and split their time between their two homes until they made South Laguna their primary residence in 1928, when a dining room and guest room were added giving the home its current L-shape. Egan continued farming until he fell ill in October 1930 and died two months later. After his death, his wife Alberta “Bertie” continued to live in the cottage until her death in 1949. The Egan residence was surrounded by farmland into the late 1930s. Part of the Egan homestead acreage was sold to residential developers or acquired by the South Coast Water District to build water reservoirs for South Laguna. The remaining acreage became undeveloped county land. The HRG report notes that Egan built three homes in South Laguna, and that the Egan Residence (31526 Valido Road) ca. 20 City of Laguna Beach Historic Resources Inventory (Resolution No. 82.111), adopted December 21, 1982. 21 City of Laguna Beach, Historic Register Index List, July 2024, https://www.lagunabeachcity.net/home/showpublisheddocument/9102/638563011154330000, accessed 12/28/2025. 22 Office of Historic Preservation, Built Environment Resource Directory (BERD), https://ohp.parks.ca.gov. 23 Sale History, Orange County Assessor.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 13 1909, is the only home of the three that remains extant today. According to HRG, “the Egan residence appears to be the last intact residence associated with homesteading in South Laguna still in existence on its original site.”
24 The period of significance identified for the property is ca. 1909-1928. According to HRG, the residence retains its one-story, L-shaped form and massing from its period of significance and still has the appearance of the 1928 cottage. While the residence has had several alterations after its period of significance (window replacement, horizontal siding, door replacement, south shed-roofed addition with deck), HRG found it still retains integrity of design, materials, workmanship, and feeling because the changes do not diminish its ability to convey its significance. However, HRG found it does not retain integrity of setting due to surrounding residential development.25 Nevertheless, in their Architectural Description, HRG states that the front ca. 1909 portion of the house has been “significantly altered”, along with the ca. 1910 wing to the south which is also “substantially altered”:

The entry features a non-original paneled door. This volume has wood board-and-batten and clapboard siding and is likely the original ca. 1909 portion of the house, although it has been significantly altered. According to an early photograph, the volume had shingle siding and a shed roof. The 1928 addition to the west appears to retain its original wood, board-and-batten siding and wood sash windows on the north and west facades. The ca. 1910 wing to the south has been substantially altered. It originally had narrow board-and-batten siding but was remodeled in 1928 with wider spaced battens and the original windows were replaced. It now has horizontal clapboard siding, and the 1928 windows have been replaced with large aluminum sliding windows. The aluminum windows and clapboard siding appear to have been added ca. 1970 at the same time as the small addition on the south wing because the construction and appearance are all similar.26
HRG did not find homesteader and farmer William F. Egan to be a significant person in South Laguna’s past under Criterion B/2, noting he was not the first nor the most important homesteader in South Laguna, he was not involved in local, state or national affairs, and there is no documentation to suggest he made a significant impact on history.27
HRG identified the existing residence as a modest typical owner-built hillside cottage property type constructed with at-hand materials (ca. 1909 cabin; enlarged ca. 1910; remodeled 1928) that retains some original features (wood board-and-batten siding, wood sash windows, one-story height, L-shape plan with cross gabled roof). HRG noted the cottage is “not unique in design or construction” and does not possess the distinctive characteristics of a particular architectural style and found it ineligible under Criterion C/3.

2. Chronicle Heritage. Historic Resource Assessment of 31526 Valido Road, Laguna Beach 92651.

April 2025. Prepared for LCRA Architecture and Planning and property owner. 24 Historic Resources Group, Historic Resources Assessment, 31526 Valido Road, Laguna Beach, November 22, 2024, page 33. 25 Ibid., 31-32.
26 Ibid., 27-28.
27 Ibid, 30-31.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 14 Chronicle Heritage (CH) undertook an independent review of land patents, County assessment records, plat maps, aerial photographs, historical newspapers, census records, and local history publications, but otherwise relied upon a peer review of HRG’s report. CH confirmed that William Egan was granted 40 acres of land for the “southwest quarter of the northwest quarter of Section five in Township eight south of Range eight west of the San Bernardino Meridian, California, on January 7th , 1910.”28 Their review did not find conclusive evidence that a building was on Egan’s land as early as 1909, however, assessment improvements recorded in 1915 may have been additions to an already extant structure.29 CH found that numerous homesteads were established within the County and enactment of the Egan Homestead is not a rare or unique event.30 Yet, CH noted that HRG substantiated their finding of eligibility on the premise that Egan’s residence is “the last vestige of the pioneer spirit that brough homesteaders to the region . . . it is still an intact representation of the early homesteads in South Laguna . . .”31 While CH found the Subject Property may indeed be the oldest intact homestead residence within the 40-acre area of William Egan’s homestead land, CH found the Egan family began selling portions of the homestead land beginning in 1934, and aerial photos indicate that areas directly surrounding the Subject Property were completely developed with residential properties by 1972.32 CH states, “any association with homesteading was lost over 40 years ago.”33 While both of these studies indicate the Subject Property may be the last remaining vestige of the Homestead Act in South Laguna, CH found the Subject Property does not retain sufficient integrity of setting due to infill development to adequately reflect or convey a significant association with the Homestead Act of 1862. Where HRG found the Subject Property eligible as a rare survivor, in contrast, CH concluded that the Subject Property does not have sufficient significance or integrity to be eligible for listing in the National Register or the California Register, nor does it appear to be eligible for listing under any of the local criteria.

CH found the Subject Property does not retain integrity of setting, feeling or association because the 1934-1972 residential development within the 40-acre homestead land originally associated with the Egan residence has destroyed the original rural agricultural setting of the Egan homestead. CH also found that due to later alterations, the subject Egan residence itself does not retain integrity of design, materials, or workmanship from its original construction.

In addition to finding the Subject Property ineligible under any of the applicable National and State Register Criteria (A/1, B/2 and C/3), CH further found the Subject Property ineligible under the Laguna Beach Criteria. CH states that the owner of the Subject Property does not consent to list the property in 28 Chronicle Heritage, Historic Resource Assessment of 31526 Valido Road, Laguna Beach 92651, April 2025, page 11 and Figure 3. Land Patent, Department of the Interior, BLM. 29 Ibid., page 13, Figure 5.
30 Ibid., page 24.
31 Ibid., page 24.
32 Ibid., page 21.
33 Ibid., page 25.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 15 the City’s historical register, and their detailed examination of the record did not indicate the Subject Property meets one or more eligibility criteria.34

3. GPA Consulting. Peer Review of Historic Assessments for 31526 Valido Road, Laguna Beach.

Prepared for the City of Laguna Beach. July 28, 2025.

While GPA agreed that HRG correctly identified Homesteading and Agricultural Development in South Laguna (ca. 1909-1928) as the relevant historic context for evaluating the Subject Property, GPA suggested “this context may be overextended and insufficiently substantiated when measured against the evaluative guidance provided in National Register Bulletin 15,” 35 which cautions that “a property must be
more than simply associated with a historical trend; it must clearly illustrate that trend or be one of the most important properties associated with it”.36 GPA states that, “in this case, HRG has not convincingly demonstrated that the Egan property rises to a level of distinctiveness, rarity, or illustrative clarity to justify significance under the broad theme of homesteading.” 37 GPA noted the Homestead Act was enacted in 1862, nearly 50 years earlier than William Egan’s 40-acre homestead claim in 1910. GPA also noted that earlier and “more robust” examples of homesteading had taken place in Southern Orange County, although not specifically in what later became Laguna Beach.

Since South Laguna was not formally named until 1934 and was not annexed into the City of Laguna Beach until 1897, GPA questioned whether it is appropriate to evaluate the property’s significance within the context of local history rather than the broader context of Southern Orange County or unincorporated Orange County rural development.

GPA also noted that HRG did not provide sufficient comparative analysis with other known homestead properties in the region to support a claim that the Egan property is a particularly important or rare surviving example. GPA concurred with CH’s finding that the setting has been substantially altered and no longer conveys its association with the early 20th-century homesteading. GPA concluded that “while the residence may retain integrity in several aspects, the loss of setting – combined with an arguably generalized historic context and absence of compelling comparative framework – undermines the strength of HRG’s argument for eligibility under Criterion 1”.38 Finally, GPA acknowledged there may be potential for historical significance under a more narrowly defined sub-context on early residential development in South Laguna, particularly given that the Egan residence is documented as one of the first homes constructed in the area.
39 4. Letter, September 18, 2025, Francesa Smith to Design Review Board. “RE: Agenda Item 5.9, Design Review 24-0658, Coastal Development Permit 24-0657.” 34 Ibid., pages 22-23 and 25.
35 GPA Consulting. Peer Review of Historic Assessments for 31526 Valido Road, Laguna Beach. Prepared for the City of Laguna Beach. July 28, 2025, page 7.
36 Ibid., pages 7-8.
37 Ibid., page 8.
38 Ibid., page 8.
39 Ibid., page 9.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 16 Francesca Smith concurred with the HRG finding that the Subject Property is eligible for the National and California registers under Criteria A and 1, for its association with the Homestead Act, and agreed that the Egan residence retains sufficient integrity to convey significance, because the residence would be recognizable to the original owner today.40 However, Smith also agreed with GPA that the HRG evaluation could benefit from a more developed context and comparisons with other similar properties to more strongly support the finding of significance.41
Smith noted that while the surrounding setting of the Subject Property has been compromised by residential development, the majority of the Egan Homestead, 24 of 40 acres, remains vacant today because much of this land was not suitable for agriculture because of the steep hillsides. This vacant 24 acres of land that originally formed the surrounding setting of the Egan residence and associated agricultural fields is today part of the Aliso and Woods Canyon Wilderness Area, a permanent wildlife conservation area. Thus, Smith found that the Subject Property still possesses sufficient integrity to convey significance under Criteria A and 1.42
As documented in Laguna Beach and the Greenbelt: Celebrating a Treasured Historic American Landscape (HALS CA-123), the majority of present-day Orange County was portioned into ranchos, and most of what is now Laguna Beach is in the area that was excluded (Figure 1). 43 The HALS report
provides an additional context for all of Laguna Beach, including South Laguna and its greenbelt, which has been recognized by the National Park Service as a Historic American Landscape. The HALS states that the oldest sections of Laguna Beach were developed at the turn of the twentieth century when small plots of homesteaded land were individually subdivided. Development occurred gradually, influenced by the homestead and rancho boundaries, traditional small-town grid street system, and the artistic community.44
Neither HRG nor CH identified any other comparative properties, which Smith argued is because extant homesteads in Laguna Beach, Orange County, and California, are extremely rare. However, Smith included a photo of the James Shrewsbury House, relocated in 1938 to 31511 Eagle Rock Way from its original location near the top of 3rd Avenue. Smith noted that the Shrewsbury House was converted into a two-story residence and is substantially altered. Smith reviewed the National and California registers but was unable to find other good comparison properties.45

5. Letter, September 19, 2025, Greg O’Loughlin to Design Review Board, “RE: Item 5.9, 31526 Valido Road.”
Greg O’Loughlin wrote on behalf of the South Laguna Civic Association that the Egan House is the only remaining intact homestead residence in Laguna Beach and asked the Design Review Board (DRB) to recognize its historical significance and stated it should not be demolished. The South Laguna Civic 40 Letter, September 18, 2025, Francesa Smith to Design Review Board, “RE: Agenda Item 5.9, Design Review 24-0658, Coastal Development Permit 24-0657, page 1.
41 Ibid., page 2.
42 Ibid., page 3.
43 Ibid., page 4.
44 Ibid., page 6; and Laguna Beach, Orange County, California, HALS CA-123, page 22. 45 Smith, page 5.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 17 Association has researched and found that the entire area of South Laguna is made up of former homesteads. In Laguna Beach, 43 homestead patents were filed, but none of the homestead houses or their outbuildings remain, except for the Shrewsbury and Egan houses. According to O’Loughlin, the Shrewsbury/Beach House was partially demolished and partially moved and incorporated into another residence on Eagle Rock Way, as mentioned above. The South Laguna Civic Association has mapped the homestead lines of South Laguna and overlaid them onto U. S. Coast and Geodetic Survey maps which show topography and structures. This analysis suggests that the Egan house (#6) is the only intact homestead house that remains extant.
46 The South Laguna Civic Association interviewed Esther Egan Hind, William Egan’s daughter, her husband Russ Hind, and Russ’ cousin Jim Hind, to learn about homestead life. Mrs. Bertie McCoy Egan, William’s wife, had a role in the development of the community, making decisions about which developers to sell her land to, and supplying the sites for two reservoirs essential for the development of South Laguna.47

6. Letter, September 19, 2025, Merrill Anderson, President, Village Laguna to Design Review Board members, “RE: Design Review for Egan homestead property at 31526 Valido Road.” Village Laguna concurred with HRG’s findings and stated that Smith’s additional research and comparisons address the research gaps identified by GPA, further supporting the eligibility of the Subject Property for listing under National Register Criterion A and California Register Criterion 1. Furthermore, Village Laguna noted that the remaining undeveloped acreage of the original 40-acre Egan homestead land remains extant and comprises a natural landscape that is now preserved as a part of the Aliso and Wood Canyons Wilderness Park that includes much of the undeveloped portion of the former Egan homestead property.48
Research Results
ESA conducted research to verify the accuracy of the previous studies and answer research questions about homesteading and the settlement and development of South Laguna. ESA found the research conducted by the previous studies was of good quality and appears to be largely accurate. However, the questions of significance and integrity still remain.

Laguna Beach Homesteaders
Upon examination of the Laguna Beach Homesteaders map provided by Village Laguna (Beryl Wilson Viebeck’s homestead map), the history of homesteading goes back to 1875 in Laguna Beach. George Thurston, Sr. (who took over Eugene Salter’s 1871 claim), was one of the earliest homesteaders in South Laguna in 1879, followed by Napoleon Wilson in 1889, and several patents in 1891 awarded to Leon W.

Goff, Sr., George Thurston, Jr., and Lafayette Thurston. The Goff family (Franklin Goff, Sr., 1883, Lulu 46 Letter, September 19, 2025, Greg O’Loughlin to Design Review Board, “RE: Item 5.9, 31526 Valido Road”, pages 1-2, and map.
47 Ibid., page 2.
48 Letter, September 19, 2025, Merrill Anderson, President, Village Laguna to Design Review Board members, “RE: Design Review for Egan homestead property at 31526 Valido Road,” page 1. 579
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 18 Goff, 1891, Leon A. Goff, Sr.,1891, and Leon Goff, Jr., 1896) also held several patents nearby in Arch Beach. Of all of the homesteads documented on the map, William Egan (1910) and James Shrewbury (1911) in Aliso, and Russell Wallace (1916) in Arch Beach, are the most recent homesteaders, at the end of the homestead settlement period in South Laguna.

Thurston Homestead (1879)
A historic image of the former Thurston homestead residence in Aliso Canyon that belonged to homesteader George Thurston, Sr., provides some additional context for comparison. In contrast to the Egan (1910) and Shrewsbury (1911) homesteads at the end of the homesteading era, the Thurston Homestead was one of the earliest in South Laguna in 1879.49 This photo from the early 1900s (Figure 2) shows a two-story wood-frame residence that is vernacular Victorian in character with a hipped roof crowned by a widow’s walk, 2/2 wood sash windows, clapboard siding and a brick exterior chimney. The associated agricultural and natural landscape is shown in Figures 3 and 4. There is a group of ancillary agricultural structures in a fenced area behind the house, a secondary dwelling and a cistern adjacent to the main house, shade and fruit trees, and cultivated farm fields in the canyon (Figure 3). An opposite view across the fields toward the house with the mountain as a backdrop is shown in Figure 4. 49 Eugene Salter was the first American settler of South Laguna in 1871; after he moved away, his 152-acre claim in Aliso Canyon and one-room shack was claimed by George Thurston, Sr. There is an excellent history of homesteaders in South Laguna in the HRG’s Historic Resources Assessment, 31526 Valido Road, Laguna Beach, November 22, 2024, pages 18-22.

Figure 1. Laguna Beach Homesteaders, 1875-1916 (Beryl Wilson Viebeck, 1996). Egan Homestead outlined in red. 580
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 19 Figure 2. Original Thurston House, Early 1900s (Michelle Boyd, “Early Days of a Pioneering Laguna Family,” The Laguna Beach Independent, March 31, 2011, from https://www.lagunabeachindy.com/page_one/schools/early-days-of-a-pioneeringlaguna-family/article_70a4a661-97a1-55f7-84df-c7befbb438e2.html, accessed 12/26/2025).

Figure 3. Thurston Homestead (Laguna Beach Historical Society.org, https://images.squarespacecdn.com/content/v1/53881470e4b04631a5e04ebb/1413093479377- JAOR0I770DGR0AUH1AP1/Thurston+Homestead+Aliso+Canyon+jpg.JPG?format=2500w, accessed 12/26/2025). 581
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 20 Figure 4. Thurston Homestead, Aliso Canyon, ca. 1920 (Laguna Beach Historical Society.org, https://lagunabeachhistory.smugmug.com/Aerial-Photos/i-LQMjxFM/A, accessed 12/26/2025).

Egan Homestead (1910)
The story of the Egan homestead and pioneer family is told by Lee C. Hanson, Ph.D., in a serialized history in Stu News Laguna, entitled “The House on Valido Road.” The land south of Thurston’s property was owned by the U.S. government and was still open for homesteading when Will Egan and James Shrewsbury came to Aliso Beach on a camping trip in 1902 and rode over the available land. The two men developed a plan and made the necessary investments of labor and materials to successfully obtain adjacent patents, for 40 acres by William F. Egan in 1910, and 160 acres by James Shrewsbury in 1911, totaling 200 acres.
50 This included clearing the land, preparation of the fields, and building a dwelling on each homestead. Egan and Shrewsbury farmed the land together and grew melons, string beans, lima beans, and squash to sell at markets in Los Angeles and San Francisco.51 According to Esther Egan,52 Will Egan and Jim Shrewsbury built the first dwelling, a 10’ x 16’ room which later became the kitchen in the Egan home and is still extant (Figure 7).
53 50 Lee C. Hanson, Ph.D., “The House on Valido Road: The Homestead Challenge”, Stu News Laguna (https://stunewslaguna.com/the-house-on-valido-road-110725/, accessed 12/29/2025). 51 “50 Cents a Pound Received For Early Beans,” The Santa Ana Register, April 10, 1920; from HRG, Historic Resources Assessment, 31526 Valido Road, Laguna Beach, November 22, 2024, page 21. 52 Second daughter of Will and Bertie, Esther Egan was born in 1912, and became the family historian. 53 “Lee C. Hanson, Ph.D., “The House on Valido Road: Dwelling, House, Home”, Stu News Laguna (https://stunewslaguna.com/the-house-on-valido-road-112125/, accessed 12/29/2025). 582
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 21 The historic appearance of the Egan homestead land is depicted in a historic photograph (Figure 5) which shows the South Laguna homestead of William Egan (far right – outlined in red) and ancillary agricultural structures (center) including farm laborer’s dwellings and other farm structures. This appears to be an example of “dry farming”. There is row of trees shading the farm structures that extends to the left outside the frame of the photograph.54 Will Egan was a farmer, blacksmith, and beekeeper.55 This photo shows the homestead dwelling, ancillary structures, farmland, roads, trees and associated natural landscape setting which are its character-defining features from the period of significance. As can be seen on the map (Figure 6) of the Egan Homestead, only approximately a third of the land within the 40-acre homestead was arable.

Figure 5. Egan Homestead ca. 1920 (Lee C. Hanson, Ph.D., “The House on Valido Road: The Homestead Honeymoon”, Stu News Laguna, Courtesy of First American Title Company, https://stunewslaguna.com/the-house-on-valido-road-111425/, accessed 2/29/2025).
54 According to the Turnbull’s the trees are extremely slow growing Cypress, and are visible in other pictures. They are in straight lines of almost one mile in length on both the north and south sides of Aliso Canyon. No one knows who planted them, not even George Thurston, the first homesteader of Aliso Canyon in 1871. “South Laguna California: An early pioneer family’s photos,” @ 1986-2025 Steve Turnbull (https://www.lightheaded.com/asite/laguna/laguna_history/south_laguna_2.php, accessed 12/26/2025). 55 Lee C. Hanson, Ph.D., “The House on Valido Road: The Homestead Honeymoon,” Stu News Laguna (https://stunewslaguna.com/the-house-on-valido-road-111425/, accessed 12/29/2025). 583
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 22 Like other homesteads, the Egan house was expanded and improved over the years. The first 10-ft x 16-ft. shed-roofed cabin with shingle siding was cheap and easy to build and fulfilled the minimum requirements of the Homestead Act. The first addition was likely made by Egan around 1909 either shortly before or after his marriage to Alberta “Bertie” E. McCoy (Figure 7). An additional section was added to the gable end of the first addition along with new windows and a fireplace in late 1909 or 1910 for the birth of the couple’s first daughter, Frances (Figure 8). In 1916, a wildfire in South Laguna destroyed much of the Egan homestead but the house thankfully survived. For several years thereafter the family focused on restoring the property and little attention could be given to improving the house. A second bedroom, updated windows, a new roof structure with exposed rafter tails and new board-andbatten siding were finally added in 1928, creating the existing L-shaped plan (Figure 9). All of the family’s water was caught and stored in cisterns with pumps (Figure 10). Because of the expense of the poles and wiring, it was years before they could bring electricity to the property.56 56 Lee C. Hanson, Ph.D., “The House On Valido Road: See How It Grew”, Stu News Laguna (https://stunewslaguna.com/thehouse-on-valido-road-120525/, accessed 12/29/2025).

Figure 6. The house was built on the rim overlooking Ceanothus Canyon. The red shape outlines the property where the house was built. The yellow square is the boundary of the 40-acre Egan homestead. Lee C. Hanson, Ph.D., “The House on Valido Road: The Homestead Honeymoon,” Stu News Laguna, https://stunewslaguna.com/the-house-on-valido-road111425/, accessed 12/29/2025). 584
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 23 An aerial photo of South Laguna in 1938 shows the Egan homestead was still undeveloped, but the land to the south had been subdivided and was being filled with residential development (Figure 11). The appearance of the homestead landscape in the 1930s is captured in family photos and paintings by local artists. Bertie Egan gave a painting of the Egan homestead “on the hill” to her daughter Esther for a wedding gift. It depicts the picturesque seaside landscape setting including several mature eucalyptus trees (Figure 12) and is said to have been displayed with a companion piece depicting a eucalyptus grove on the property, which suggests Egan may have also fulfilled the requirements of the Timber Culture Act of 1873 by planting 10 acres of trees by 1910. After Will Egan’s sudden death in December 1930, Bertie chose to keep her daughters close, gifting them each a half-acre of land for their own homes, just down the hill from her home. Esther’s house was built in June 1935 during the year before her wedding. A historic photo shows that Esther’s house was built in an area with several mature eucalyptus trees similar to the site depicted in the painting (Figure 13).
57 The Egan family retained ownership of their family
home until it was sold in 1956.58 The tract on the hill above the home was subdivided and being graded for residential development in 1952 and by 1972 the land surrounding the Egan home had been fully developed with a residential neighborhood.59
57 Lee C. Hanson, Ph.D., “The House on Valido Road: See How it Grew,” Stu News Laguna (https://stunewslaguna.com/thehouse-on-valido-road-120525/, accessed 12/29/2025). 58 Chain of Title for 31526 Valido Road, Orange County Archives, from HRG, Historic Resources Assessment, 31526 Valido Road, Laguna Beach, November 22, 2024, page 23.
59 HistoricAerials.com, 1952, 1972, from Chronical Heritage, Historic Resources Assessment of 31526 Valido Road, Laguna Beach 92561, April 2025, page 14 and 15.

Figure 7. Original cabin (left), ca. 1909; and first gable-roofed addition (right), ca. 1909-1910. (Courtesy of Deborrah Allen, representing the Egan family, from Lee C. Hanson, Ph.D., “The House on Valido Road: See How It Grew”, Stu News Laguna, https://stunewslaguna.com/the-house-on-valido-road-120525/, accessed 12/29,2025). 585
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 24 Figure 8. Original shed-roofed cabin (left) built ca. 1909, and the chimney with the two-part gable-roofed addition, built ca. 1909-1910. A grove of trees and agricultural buildings are visible to the right (south) of the structures. (Courtesy of Deborrah Allen, representing the Egan family, from Lee C. Hanson, Ph.D., “The House on Valido Road: See How It Grew”, Stu News Laguna, https://stunewslaguna.com/the-house-on-valido-road-120525/, accessed 12/29,2025). 586
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 25 Figure 9. Third bedroom addition, updated windows, new roof, and new board-and-batten siding, 1928. Tall trees and an electrical pole are visible in background. (Courtesy of Deborrah Allen, representing the Egan family, from Lee C. Hanson, Ph.D., “The House on Valido Road: See How It Grew”, Stu News Laguna, https://stunewslaguna.com/the-house-on-valido-road120525/, accessed 12/29,2025).

Figure 10. Historic photo showing water cisterns and propane tank (no date); the woman walking toward the kitchen could be Bertie Egan. (Courtesy of Deborrah Allen, representing the Egan family, from Lee C. Hanson, Ph.D., “The House on Valido Road: See How It Grew”, Stu News Laguna, https://stunewslaguna.com/the-house-on-valido-road120525/, accessed 12/29,2025). 587
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 26 Figure 11. South Laguna Beach, 1938. Egan residence circled in yellow. Terrain and landscape surrounding Egan residence is still largely undeveloped while land to south is filled with residential development (County of Orange, Historical Aerial Imagery, from Lee C. Hanson, Ph.D., “The House on Valido Road: See How it Grew”, Stu News Laguna, https://stunewslaguna.com/thehouse-on-valido-road-120525/, accessed 12/29,2025). 588
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 27 Figure 12. Painting of Egan Homestead “on the hill”, by Laguna Beach artist Lee Hayes, wedding gift to Esther Egan in 1935 from her mother, Bertie Egan, depicts eucalyptus trees and was displayed with a companion piece depicting a eucalyptus grove on the property. (Courtesy of Deborrah Allen, representing the Egan family, from Lee C. Hanson, Ph.D., “The House on Valido Road: See How It Grew”, Stu News Laguna, https://stunewslaguna.com/the-house-on-valido-road-120525/, accessed 12/29,2025).

Figure 13. William and Bertie’s daughter Esther Egan’s house, 1935, sited between eucalyptus trees (Courtesy of Deborrah Allen, representing the Egan family, Lee C. Hanson, Ph.D., “The House on Valido Road: See How it Grew”, Stu News Laguna, https://stunewslaguna.com/the-house-on-valido-road-120525/, accessed 12/29/2025). 589
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 28 Shrewsbury Homestead (1911)
Based upon available information, it appears the only other remaining extant homestead residence in South Laguna to use as a comparison with the Egan residence is the James Shrewsbury House (Figure 14), relocated in 1938 to 31511 Eagle Rock Way from its original location near the top of 3rd Avenue. As an altered vernacular dwelling that has been moved from its original location, it would not normally be eligible for listing in the National Register; however, considering the rarity of this property type, evaluation may be warranted to determine if it may be eligible for the National Register under Criteria Consideration B “as a building removed from its original location but which is significant primarily for its architectural value, or which is the surviving structure most importantly associated with a historic person or event.” As a rare surviving “altered” vernacular dwelling (remodeled from a 1-story into a 2-story residence) which is associated with the history of homesteading in Laguna Beach, it is also recommended for evaluation for local listing.

Figure 14. Shrewsbury House, relocated in 1938 to 31511 Eagle Rock Way (realtor.com, https://www.realtor.com/realestateandhomes-detail/31511-Eagle-Rock-Way_Laguna-Beach_CA_92651_M20816-92564, accessed 12/27/2025).
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 29 Existing Conditions
Survey Study Area
The Survey Study Area included the 14,071 square foot Subject Property located at 31526 Valido Road (Assessor’s Parcel 056-062-25) (Figures 15 & 16). Legal Description: S TWP 8 RGE 8 SEC 5 SEC 5 T 8 R 8 POR SW1/4 NW1/4 (Orange County Assessor).

In addition, the associated former 40-acre homestead tract, as visible from the public right of way was also investigated; 24 of 40 acres remains undeveloped vacant land, while 16 acres are fully developed.

Figure 15. Location Map, 31526 Valido Road (Orange County Assessor) Figure 16. Assessor’s Map Book 056 Page 06 County of Orange. 591
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 30 31526 Valido Road
The exterior and interior of the existing 1-story residence at 31526 Valido Road, the exterior of the ancillary detached 1-story garage (interior not accessible), and the associated surrounding landscape of the existing 14,071 square foot Subject Property was visually inspected and photographically documented, including the existence of heritage trees, if any. The visual and physical evidence was compared with historic photographs, aerial views, and construction history.

In addition, the associated land within the former 40-acre farmstead tract, as visible from the public right of way, was visually examined and photographically documented, including the existence of heritage trees, old farm structures, remnants of farm fields, or irrigation ditches, if any. The visual evidence was compared with historic photographs and aerial views.

Residence (ca. 1909 – 1928 with later alterations)
The date of construction recorded by the Orange County Assessor for the single-family residence is 1910, the year the homestead was patented, January 17, 1910,60after the homestead requirements had been fulfilled including construction of the original cabin. As discussed above, the existing 2-bedroom, 1-bath, 1,113 square foot residence was erected by William Egan in sections over the years between ca. 1909 and 1928, to meet the needs of his growing family. Based upon historic photos above (Figures 5 and 8) and historic aerials (1938, 1947)61 it appears the associated ancillary agricultural buildings, eucalyptus grove and row of cedar trees were formerly situated south of the Egan residence. They are no longer extant due to later residential redevelopment, just as the associated farmland formerly to the south, east, and west of the Egan residence has been entirely redeveloped.

The residence is situated approximately in the center of the 14,071 square foot parcel (Figure 15). The Subject Property is currently accessed by a steep asphalt driveway from Valido Road (Figure 17). The driveway and parking area were graded and paved between 1958-1962. 62 The ca. 1960 Garage is located
south of the residence (Figure 18). The property perimeter is fenced and there are several adjacent twostory single-family residences to the south and east of the Subject Property. The north yard of the Subject Property overlooks a steep canyon and Aliso Peak is visible to the north (Figures 19 and 20). The trailhead for Valido Trail is approximately 135 feet east of the Subject Property off Valido Road. There is an existing eucalyptus tree along Valido Trail that may be associated with the Egan Homestead or may be a descendent of one of the original trees (Figure 20). This vacant land is now a nature reserve and was formerly part of the Egan Homestead.

Upon physical inspection, ESA found that the Subject Residence is built of wood-frame, single-wall construction, a predominant building method found in vernacular dwellings and Beach Cottages in 60 Land Patent Number 104561, Department of the Interior, Bureau of Land Management. Copy of original patent reproduced in Chronicle Heritage, Historic Resource Assessment of 31526 Valido Road, Laguna Beach 92651, Figure 3, page 12. 61 Historic Resources Group, Historic Resources Assessment, 31526 Valido Road, Laguna Beach, pages 38 and 39. 62 Morgan Paving Co., “Pave drive-parking area” Oct. 14, 1958, $309.05, sold to Mr. & Mrs. Curtis Neiswender, Valido Road; Morgan Paving Co., “Grade out & pave add’l parking” Aug. 9, 1961, $112.18, sold to Mr. and Mrs. Curtis Neiswender, 31526 Valido Rd.; County of Orange, Highway Department, Permit No. 4793, “To bread curb and install concrete driveway approach for private residence,” Dec. 26, 1962.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 31 Laguna Beach in the early 1900s.63 The existing L-shaped dwelling (Figure 21) is framed in sections, consistent with the building chronology represented in the historic photographs above (Figures 7, 8 and 9). The exterior of the south wing appears to have been updated with aluminum windows, horizontal siding, and a wood deck (severely deteriorated) at the southwest corner (Figure 21). There are two openings that provide access to the crawl space under the house where the structure is visible. The woodframe structure of the north horizontal wing has wood joists that sit on wood piers, some of which are cut log/timber that are sitting on the ground, while the supporting joists of the south wing are sitting on concrete blocks and wood piers that are sitting on the ground.

The earliest portion of the residence is the kitchen at the east end of the north horizontal wing (Figure 22). The kitchen has single-wall construction, low wood ceiling, and is covered by the original low pitch shed roof, with a later gable roof above (Figure 23). There is an enclosed porch under the overhang of the gable roof on the east side of the kitchen that provides access to the kitchen and laundry (Figure 24). The laundry is in the utility room at the northeast corner of the north wing. The built-up construction of the existing gable roof over the kitchen and porch (Figure 25) indicates the existing gable roof was constructed over the original kitchen, likely in 1928 when the residence was remodeled and enlarged, incorporating the original one-room homestead cabin (Figure 26).

The kitchen opens into a dining area that was once the living area of the one-room cabin (Figure 27).

There is a walk-in pantry with storage shelves off the north side of the kitchen (Figure 28). The kitchen and dining area have red-colored ca. 1950s cabinetry inserts (not built in). However, there is a large builtin hutch on the south wall of the dining area, adjacent (east) to the ca. 1910-bedroom additions (Figure 30). There is a bathroom addition along the right-had side of the hall (remodeled) (Figures 31 & 32). The 1928-bedroom addition is attached to the end of the hall. The break between the sections of the house is visible at the junction of the hall with the bedrooms (Figure 33).

The south wing of the house consists of a living room along the west facing side (Figure 34), and two bedrooms along the east facing side of the wing (Figures 35 & 36). There is an exterior entrance from the deck to the south end of the living room in the south wing (Figure 34). The existing brick chimney serves as a flue for a wall heater located on the interior wall between the east and west facing rooms (Figures 34 & 36). The floor, some of the walls and most of the ceiling finishes appear to have been updated in the 1960s-1980s.

The bathroom and west wing additions are visible on the exterior of the north façade (Figures 39 & 40).

The aluminum window replacements, horizontal siding, south deck, and south bedroom extension are later alterations from the 1960s-1980s (Figures 21, 22, 41, 42).

The garden on the south side of the house has remnants of an old stone retaining wall, a planting bed, and stone path (Figure 43).
63 Information on Beach Cottage Architecture is provided in HRG’s Historic Resources Assessment, 31526 Valido Road, November 22, 2024, on page 23.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 32 Garage (ca. 1960)
There is a 1-story wood-frame gable-roofed detached garage located at the top of the driveway. Based upon review of historic aerial photos, it appears the Garage was added to the property around 1960. 64 Records indicate it was originally constructed as a carport and later converted to a garage around 1996.

The exterior is clad with vertical wood board-and-batten and plywood. The north elevation is covered by wood board-and batten siding and there is a single-leaf entrance door (Figure 44). To the left/east of the door there is a six-lite horizontal fixed wood window. The west side of the garage has board-and batten siding and a similar fixed six-lite horizontal wood window (Figure 45). The east elevation is covered with plywood and has large garage doors (Figure 46). The south side of the garage consists of approximately 50% plywood siding and 50% vertical board-and-batten with a small closed (boarded) rectangular opening (Figure 46). The Garage has concrete foundation, a low-pitched gable roof supported by wood posts and minimal wall framing (Figure 47).

Evaluation of Historic Significance
As discussed above, several previous studies have concluded that the Subject Property is significant under Criterion A/1 for its association with the Homestead Act of 1862, while one previous study (CH) found the Subject Property ineligible because of adverse changes to its integrity of setting. ESA concurs with the Peer Review prepared by GPA Consulting which concludes that the subject property does not qualify for listing in the either the National Register or the California Register under Criterion A/1 due to its association with homesteading in the South Laguna area. The broader historic context does not support eligibility under Criterion A/1. The Egan Homestead was claimed in 1910, at the end of the homestead era in Laguna Beach (1875-1916), 48 years after the Homestead Act of 1862, and 31 years after the first homestead claim in South Laguna. In comparison, the Egan Homestead was claimed 31 years after the Thurston Homestead, which was claimed by George Thurston, Sr. and his wife Sarah in 1879. The Thurston family including Lafayette Thurston and George Thurston, Jr., also claimed land in 1891, and played a role in the early settlement and development of South Laguna. Therefore, while the Egan Homestead is part of this historical trend, it has not been convincingly demonstrated that the Egan Homestead rises to the level of significance necessary for designation within the broad theme of homesteading.

As discussed above, the Egan Homestead is representative of the last 7 years of homesteading in Laguna Beach, from ca. 1909 – 1916 (Figure 1). Based upon available documentation it appears to be the last remaining intact homestead residence in South Laguna, and the majority (24 acres) of the original 40 acres of the Homestead land remains vacant and retains integrity as a vernacular landscape. The period of significance is ca. 1909 – 1928 reflecting the time when William Egan first built the Homestead cabin (ca. 1909), filed for the homestead claim (1910), and expanded the house for wife Bertie and their two daughters (through 1928). While the ancillary agricultural structures and agricultural fields have been replaced over the years by later residential development, the Subject Property remains as one of the last 64 A 1996 city inspection report recorded the illegal conversion of a carport into a garage. Although there is no permit for either a carport or a garage (City of Laguna Beach Department of Community Planning Complaint Form, No. 96-006, January 8, 1996); a 1960 aerial photograph shows a detached structure to the southeast of the residence; the first building permit on record to include the detached garage was issued in 2005 for reroofing the house and garage (City of Laguna Beach Building Permit No. 805-2491 and 2492, issued December 14, 2005); from HRG’s Historic Resources Assessment, 31526 Valido Road, November 22, 2024, page 27, and aerial photograph on page 41. 594
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 33 physical representations of this pattern of settlement and land use in South Laguna, and the associated vernacular landscape including the canyon and hills to the north are largely unchanged from their historic appearance. Nonetheless, the integrity of the Egan Homestead as a whole has been substantially compromised by later development of 16 acres of the original 40-acre homestead claim which has substantially changed the immediate setting surrounding the Egan residence, including the area where the agricultural buildings and farm fields were formerly situated and are no longer extant.

Given that the Egan residence and the remaining 24 acres of associated vacant homestead land is one of the last surviving historic-era settlements in the area, ESA concurs with GPA’s acknowledgement that there may be some potential for local historical significance associated with early rural residential development in South Laguna. Nonetheless, ESA found the existing conditions of the Subject Property to be poor and it may not be feasible to rehabilitate the existing residence for current residential use without substantial adverse impacts to the historic integrity of its character-defining features.

Character Defining Features
As discussed above, the subject parcel, 31526 Valido Road, has several relevant characteristics within the Subject Property and the vacant land to the north that contribute to the historic character of the vernacular residence and landscape associated with the Egan Homestead including:
• Steep natural topography of the canyon and hills to the north within 24 of the former 40 acres of the original Homestead and remnants of original eucalyptus grove planted by Egan. • Original ca. 1909 Homestead Cabin and its ca. 1910 and 1928 additions (Egan residence). • L-shaped plan of existing Egan residence that was built in sections. • One-story height
• Single-wall construction of the Egan residence
• Board-and-batten siding (1928)
• Single interior brick chimney
• Cross gable roof with extended eaves and exposed rafters • Enclosed kitchen porch and attached utility room.
• Simply framed rectangular window openings with wood frames and sashes. 595
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 34 Analysis of Project Impacts
Thresholds of Significance and Criteria for Adverse Impacts CEQA Guidelines
Significance Thresholds
The thresholds for determining the significance of environmental effects on historical resources identified below are derived from the CEQA Guidelines as defined in §15064.5. Pursuant to this guidance, a project that would physically detract, either directly or indirectly, from the integrity and significance of the historical resource such that its eligibility for listing in the National Register, California Register or as contributor to the potential District would no longer be maintained, is considered a project that would result in a significant impact on the historical resource. Adverse impacts, which may or may not rise to a level of significance, result when one or more of the following occurs to a historical resource: demolition, relocation, conversion, rehabilitation, or alteration, or new construction on the site or in the vicinity.

CEQA Guidelines
According to the State CEQA Guidelines, Section 15064.5(b) a project involves a “substantial adverse change” in the significance of the resource when one or more of the following occurs:
• Substantial adverse change in the significance of an historical resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired. • The significance of a historical resource is materially impaired when a project:

A. Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for inclusion in, the California Register of Historical Resources; or B. Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to Section 5020.1(k) of the PRC or its identification in a historical resources survey meeting the requirements of Section 5024.1(g) of the PRC, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or C. Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.

Secretary of the Interior’s Standards (Standards)
As mentioned above, under CEQA, a project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing, Historic Buildings or the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (1995), Weeks and Grimmer, (Standards) shall be 596
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 35 considered as mitigated to a level of less than a significant impact on the Historical Resource.65 The Standards were developed by the U.S. Department of the Interior as a means to evaluate and approve work on historic buildings for federal grants and rehabilitation tax credits. The Standards are codified at 36 Code of Federal Regulations (CFR) Section 67.7. CEQA recognizes the value of the Standards by using them to demonstrate that a project that generally follows the Standards shall be considered as mitigated to a level of less than a significant impact and may be approved without an EIR.66 In effect, CEQA has a “safe harbor” by providing either a categorical exemption or a negative declaration for a project which meets the Standards. See State CEQA Guidelines Section 15331 and 15064.5(b)(3).

However, failure to strictly comply with the Standards may not result in significant impacts to a historical resource if the project does not result in material impairment that would detract from its eligibility.

Proposed Project Impacts
The Proposed Project would demolish the existing residence, regrade the Subject Property, construct a new 2-story contemporary residence and modernize the landscape. From a conservative perspective, if the Subject Property is considered a potentially eligible historical resource, the Proposed Project would result in a significant adverse impact on the Egan residence and what remains of the associated Homestead landscape in the surrounding vicinity (24 of the original 40 acres) immediately north of the Subject Property. The demolition of the Subject Property would result in a potentially significant physical impact to the Egan residence, and the construction of the Proposed Project could result in a potentially adverse indirect visual impact to the remaining vacant vernacular landscape within the former Homestead land with view of the Subject Property.

Analysis of Project Options

1. A project that would retain a significant combination of character-defining features associated with a historical resource, in this case the Egan Homestead residence and landscape, and is designed to conform to the Standards would result in a less than significant impact to the potential historical resource pursuant to CEQA impact thresholds. Under the Standards for Rehabilitation, minimal change is allowed to support a compatible change in use. Under CEQA, minimal changes are allowed, as long as the eligibility of a property is preserved, and appropriate preservation methods are used to reduce potential adverse impacts that may be caused by alterations, additions, or adjacent new construction necessary to rehabilitate the building or property for its new use. However, it may not be feasible to rehabilitate the Egan Homestead residence for current residential use without substantially detracting from the integrity of its character-defining features because of the poor condition of the subject property. Major structural upgrades would likely be required to meet current permit requirements and living standards which would result in extensive alteration and/or replacement of the existing features.

2. If conformance with the Standards is not feasible, a project that would record the Subject Property in a publicly accessible Historic American Buildings Survey (HABS) report, including professional large format photographs, written history and documentation, and measured drawings, and, if feasible, would relocate the original homestead cabin to an appropriate 65 California Environmental Quality Act, 15064.5 (3).
66 Ibid.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 36 compatible site preferably within the Homestead land or in South Laguna, would thereby preserve the significant features and associations of the Subject residence and thus would result in a less than significant adverse impact under CEQA.

3. If relocation is not feasible, it is recommended that a HABS report be prepared as described above in Option 2, and that, if feasible, an interpretive program be developed that would include a publicly accessible historic marker commemorating the history of the Subject Property to be located near the trailhead of the Valido Trail within the area of the Egan Homestead land.

Recordation and interpretation would benefit the public by preserving the history of the Egan Homestead and homesteading in South Laguna.

Given the site’s lack of historical eligibility for the reasons set forth above, combined with the infeasibility of rehabilitation and/or relocation, Option 3 may make the most sense as additional conditions of approval.
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 37 Figure 17. Entrance driveway, view to south (M. Jerabek, ESA).

Figure 18. Garage and parking area, view to north (M. Jerabek, ESA). 599
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 38 Figure 19. North edge of yard showing fenceline with view of canyon below and Aliso Peak above, that are part of the former Egan Homestead land, view to north (M.

Jerabek, ESA).

Figure 20. Northeast corner of Subject Property showing view up canyon with eucalyptus tree, view to northeast (M. Jerabek, ESA).
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 39 Figure 21. Egan residence, west façade, view to east (M. Jerabek, ESA).

Figure 22. Egan residence, east façade, view to west (M. Jerabek, ESA). Red arrow points to location of kitchen in original one-room cabin. 601
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 40 Figure 23. Kitchen, entrance porch and utility room at northeast corner of Egan residence, view to northwest (M. Jerabek, ESA).

Figure 24. Entrance porch to kitchen (left) that also provides access to utility room, view to north (M. Jerabek, ESA).
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 41 Figure 25. Kitchen ceiling and original shed roof (ca. 1909) and built-up gable roof above (1928), view to west (M. Jerabek, ESA).

Figure 26. Roof framing showing gable roof extending over kitchen in original oneroom homestead cabin (outlined in red), view to west (M. Jerabek, ESA). 603
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 42 Figure 27. View from kitchen into dining area, with bathroom (right side of hall) and third bedroom (end of hall), view to west (M. Jerabek, ESA).

Figure 28. Pantry off kitchen, view to north (M. Jerabek, ESA). 604
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 43 Figure 29. View of dining area back toward kitchen, view to east (M. Jerabek, ESA).

Figure 30. View from dining area toward ca. 1910-bedroom additions (outlined in red); ca. 1928-bedroom addition at end of hall (right); view to southwest (M. Jerabek, ESA)
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 44 Figure 31. Hall, view to west (M. Jerabek, ESA).

Figure 32. Bathroom, view to north (M. Jerabek, ESA).
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 45 Figure 33. Junction of Hall with south wing where construction overlaps (M. Jerabek, ESA).

Figure 34. South wing, interior of west facing living room, view to south (M. Jerabek, ESA) 607
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 46 Figure 35. Bedroom No. 2 interior, east side at south end of south wing, view to west (M. Jerabek, ESA).

Figure 36. Bedroom No. 1 interior, east side of south wing, view north toward kitchen (M. Jerabek, ESA).
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 47 Figure 37. Bedroom No. 3, interior, view to west (M. Jerabek, ESA).

Figure 38. Interior detail, windows on north wall of Bedroom No. 3, view to north (M. Jerabek, ESA). 609
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 48 Figure 39. Exterior of north façade, view to south (M. Jerabek, ESA).

Figure 40. Exterior, west end of north horizontal wing, view to east (M. Jerabek, ESA). 610
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 49 Figure 41. Exterior, southwest corner deck addition (deteriorated) and bedroom extension, with horizontal siding (later alterations), view to north (M. Jerabek, ESA).

Figure 42. Exterior, south end of south wing showing later alterations including bedroom extension, aluminum windows, horizontal siding, view to west (M. Jerabek, ESA).
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 50 Figure 44. Garage, north façade, view to south (M. Jerabek, ESA).

Figure 43. South yard with old stone retaining wall, planting bed, and stone path, view to north (M. Jerabek, ESA).
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 51 Figure 46. Garage, view to north (M. Jerabek, ESA).

Figure 45. Garage, west elevation, view to east (M. Jerabek, ESA). 613
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Historic Resource Technical Memorandum for 31526 Valido Road, Laguna Beach, CA 52 Figure 47. Garage, interior, view to south (M. Jerabek, ESA). 614
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 1 MEMO
TO: CITY OF LAGUNA BEACH
ATTN: HEATHER STEVEN, SENIOR PLANNER
FROM: LAURA JANSSEN, SR. ARCHITECTURAL HISTORIAN;

MARIANA RUIZ, ARCHITECTURAL HISTORIAN
DATE: MARCH 23, 2026
Introduction
Historic Resources Group (HRG) submitted a historic assessment report for the property at 31526 Valido Road in the City of Laguna Beach in November 2024 and a revised report in February 2025. An independent historic assessment report of the property by Chronicle Heritage was submitted to the City in April 2025.1 HRG provided a supplemental memo to comment on the report’s conclusions in June 2025. In July 2025, GPA Consulting submitted a peer review of both reports.2 This memo will respond to GPA’s peer review of HRG’s report.

Generally, GPA did not find fault with HRG’s methodology or research conclusions; however, they did not agree with the finding that the subject property appears eligible for listing in the National Register of Historic Places (NRHP) at the local level or the California Register of Historical Resources (CRHR). They did not find sufficient evidence to support the idea that the property at 31526 Valido Road meets the eligibility criteria for listing in either the California Register or the National Register. GPA only provided an evaluation of whether HRG’s conclusions were supported by the facts and did not provide a third independent assessment of the property. HRG will only respond to comments made regarding their report and not comment on the evaluation of the Chronicle Heritage report. 1 “Historic Resource Assessment of 31526 Valido Road,
Laguna Beach 92651,” prepared by Chronicle Heritage, April 2025.
2 “Peer review of Historic Resource Assessments for 31526 Valido Road, Laguna Beach,” prepared by GPA Consulting, July 28, 2025.
556 S. Fair Oaks Ave., Suite 101-514
Pasadena, CA 91105
Attachment 22
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 2 HRG’S RESPONSE
HRG has no response to the first three items of GPA’s peer review. HRG’s responses begin with Item 4 and follows and corresponds to the highlighted sections and bold lower case letters below. The paragraphs below are clipped from pg. 7 under Item 4 of GPA’s Peer Review:

4. We also review whether the conclusions regarding historical significance (or lack thereof) are supported by substantial evidence, as defined in National Register Bulletin 15 and related relevant guidance. This includes assessing whether the property was evaluated for the correct area(s) and level(s) of significance (local, regional, state, or national), whether appropriate integrity aspects were considered, and whether the property retains sufficient integrity to convey its significance. We examine whether the subject property has been appropriately compared to similar properties within the same historic context and whether the narrative argument clearly establishes that the property is not only historic but significant under the applicable criteria.

In their February 12, 2025 report, Historic Resources Group (HRG) evaluated 31526 Valido Road within the historic context of “Homesteading and Agricultural Development in South Laguna (ca. 1909–1928)”. This context emphasizes the early 20th-century EuroAmerican settlement of South Laguna, specifically through land claims made under the Homestead Act of 1862. HRG links the property to this context through its association with William F. Egan, who filed a 40-acre homestead claim in 1910, constructed the original cabin around 1909, and actively farmed the land with his family into the late 1920s. The property’s significance is evaluated solely under California Register Criterion 1 (and National Register Criterion A) for its connection to early homesteading activity in the area. HRG does not assert eligibility under other criteria. The defined period of significance (ca. 1909–1928) reflects the timeframe during which the property developed and functioned as a working homestead.

While HRG identifies “Homesteading and Agricultural Development in South Laguna (ca. 1909–1928)” as the relevant historic context for evaluating the property, this context may be overextended and insufficiently substantiated when measured against the evaluative guidance provided in National Register Bulletin 15, which also underpins the California Register criteria. Bulletin 15 cautions that “a property must be more than simply associated with a historic trend; it must clearly illustrate that trend or be one of the most important properties associated with it.” In this case, HRG has not convincingly demonstrated that the Egan property rises to a level of distinctiveness, rarity, or illustrative clarity to justify significance under the broad theme of homesteading (a).

Although William Egan filed a 40-acre homestead claim in 1910 and constructed the original cabin ca. 1909, the Homestead Act was enacted nearly 50 years earlier in 1862, and many earlier and more robust examples of homesteading occurred in Southern Orange County—not specifically in what later became Laguna Beach (b). In fact, South Laguna was not formally named until 1934 and was not annexed into the City of Laguna Beach until 1987, calling into question whether it is appropriate to evaluate the property’s significance solely within the context of Laguna Beach’s local history, rather than in the broader regional context of Southern Orange County or unincorporated Orange County 625
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 3 rural development (c).

Additionally, HRG does not provide sufficient comparative analysis with other known homestead properties in the region to support a claim that the Egan property is a particularly important or rare surviving example (d). Chronicle rightly critiques this point, emphasizing that the setting has been substantially altered, and without the surrounding agricultural context, the property no longer clearly conveys its claimed association with early 20th-century homesteading. While the residence may retain integrity in several aspects, the loss of setting (e)—combined with an arguably generalized historic context and absence of a compelling comparative framework—undermines the strength of HRG’s argument for eligibility under Criterion 1.

HRG response:
a) Rarity of the Egan Homestead - HRG conducted additional research on the history of homesteading in Orange County to better understand the historic significance of the Egan Homestead. (See “Homesteading in Orange County” historic context below.) This research has revealed that homesteading in Orange County at the end of the nineteenth century was very limited due to the large, private landholdings of the California ranchos, as well as to the land grants acquired by the transcontinental railroad. In order to acquire property, early settlers were forced to either purchase land from the railroad companies or to homestead federal land limited to the rugged terrain of the Santa Ana Mountains, the lower San Joaquin foothills, or on unclaimed land between bordering ranchos (Laguna Beach). Of the 1,467 homestead declarations in Orange County3 recorded through 1940, approximately 70 homesteaders were successful in acquiring land patents, according to historian Josh Sides.4 This small number of homesteaders faced extreme hardship, isolation, intense physical labor, and limited resources, to survive in the rugged terrain they were left to occupy.

In the Santa Ana Mountains, the establishment of Cleveland National Forest in 1893 limited the development of the canyons further. Only early homesteaders with legal claims within the boundaries of the Cleveland National Forest were allowed to sustain private property in the area. Homesteading in Laguna Beach, conversely, prospered while the city ultimately developed into a flourishing beach community surrounded by a greenbelt of natural landscapes with mountains and dramatic canyons, coastal cliffs, caves and arches, and ever-changing ocean views. In 2016, the Laguna Beach greenbelt was documented under the Historic American Landscape Survey (HALS).5
3 California Department of Transportation, “A Historical Context and Archaeological Research Design for
Agricultural Properties in California,” 2007, 42.
4 Josh Sides, Backcountry Ghosts: California Homesteads and the Making of a Dubious Dream (University of
Nebraska Press, 2021), e-book, 212.
5 National Park Service, “Historic American Landscape
Survey Laguna Beach (HALS-CAL 123)” 2016. The
Historic American Landscapes Survey (HALS) is the
National Park Service (NPS) program dedicated to
documenting historic landscapes across the U.S. and its territories. Founded in 2000, HALS creates permanent
records—including photographs, histories, and drawings— of significant sites, such as gardens, public spaces, and agricultural areas, which are then archived in the Library of Congress.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 4 The Egan Homestead is the only intact homestead residence within the present-day area of Laguna Beach, and it appears to be the only surviving homestead residence in the whole of Orange County. Additional research ruled out James Shrewsbury’s homestead residence, now located at 31511 Eagle Rock Way in Laguna Beach.

Unlike the Egan residence, the Shrewsbury house was relocated from its original location near the top of Third Avenue in South Laguna in the 1930s and converted into a two-story residence.6 Due to modern alterations and its relocation from the original homestead, the Shrewsbury house does not retain its association with homesteading or retain sufficient integrity to be listed in the CRHR or NRHP.7 This additional research further supports the Egan Homestead residence is a rare and intact example of early twentieth century homesteading in Orange County. b) The Homestead Act and its impact on western development – The Homestead Act of 1862 was a significant piece of legislation aimed at promoting the settlement and development of the American West. The original act allowed any American, including freed slaves, to put in a claim for up to 160 acres of federal land, provided they improved the land by building a dwelling and cultivating crops. This act was a cornerstone of westward expansion, encouraging millions of Americans to migrate west in search of new opportunities.8
By the early twentieth century, additional versions of the Homestead Act were enacted to address various challenges and expand the opportunities for settlement.

The Enlarged Homestead Act of 1909 increased the amount of land available to settlers to 320 acres, recognizing the need for larger tracts of land to sustain agricultural operations in the more arid regions of the West. The Stock-Raising Homestead Act of 1916 further expanded opportunities by allowing settlers to claim 640 acres of land primarily for livestock grazing, acknowledging the different agricultural needs of the western territories.9 The Homestead Act remained in effect until 1976, with limited provisions in Alaska continuing until 1986 – superseding the period of significance for the Egan Homestead (ca. 1909-1928) and the establishment of South Laguna in 1934 by approximately fifty years. Although it was modified and expanded, the opportunities provided by the Homestead Act were not limited to the first fifty years after it was enacted. Over 270 million acres – roughly 10% of the area of the United States – were transferred to private citizens by 1986.10 Early homesteads in Orange County all reveal similar characteristics – a small cabin, a farmstead, an agricultural farm and/or apiary – on varying acreage of land. In some cases, wealthy settlers purchased multiple homestead claims and adjoined railroad property, to develop large ranches or estates, such as the Adkins Ranch or the 6 Francesca Smith, [letter dated September 18, 2025, Re.

Agenda Item 5.9, Design Review 24-0658, Coastal
Development Permit 24-0657,] City of Laguna Beach
Notice of Appeal for 31526 Valido Road, October 8, 2025. 7 31511 Eagle Rock Way is currently listed in the Laguna Beach Historic Register, but not for its association with homesteading, rather as an example of a 1930s-era bungalow. 8 “[California Homestead Map] Department of the Interior State of California,” Barry Lawrence Ruderman Antique
Maps,
https://www.raremaps.com/gallery/detail/104408/californi a-homestead-map-department-of-the-interior-st-usgeological-survey, accessed May 2025. 9 “[California Homestead Map] Department of the Interior State of California.”
10 “About the Homestead Act,” National Park Service,
https://www.nps.gov/home/learn/historyculture/abouthomes teadactlaw.htm, accessed March 2026.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 5 Modjeska estate. These more robust properties, although agricultural and/or rural in nature, are not considered historically homesteads granted through federal land patents under the Homestead Act of 1862 or one of its subsequent amendments.

The Egan Homestead, conversely, was a land grant under the Homestead Act and remained a working agricultural property into the late 1920s and remains the only intact residence associated with homesteading in Orange County. It unclear how GPA could make a claim that there are “many earlier and more robust examples of homesteading in southern Orange County,” when they did not perform any additional research.
c) Historic Context – HRG initially chose to evaluate the Egan Homestead within the context of Laguna Beach’s local history due to the property’s significance within the early history of the area. CRHR and the NRHP criteria at the local level of significance, evaluates buildings, sites, districts, structures, or objects based on their significance to a local community’s history, architecture, development patterns, or influential local persons, rather than national or state history.11 Because homesteading, including the Egan Homestead, was a catalyst for development in South Laguna, it was appropriate to evaluate its significance within the context of Laguna Beach’s history, but in response to GPA’s comments HRG has developed a broader context of “Homesteading in Orange County.”
The HALS documentation in 2016 was meant to emphasize the fact that the area’s dramatic landscape was the basis of the development of Laguna Beach. In the “Landscape Character” description, the HALS documentation states: “The enclaves formed by these hills are the basis for the city’s character. The slopes on the coastal side are composed of terrace material eroded over the years from the hillsides and include relatively deep soils that were farmed by early homesteaders. They were among the first to be developed, as they were easy to reach and build upon.”12 Moreover, examining the Egan Homestead within the broader context of “Homesteading in Orange County,” has further supported the rarity of the Egan Homestead residence, as the only extant homestead dwelling that retains historic integrity in the County.
d) Comparative Analysis – HRG conducted research into the history of homesteads in Orange County and concluded that the Egan Homestead is the only surviving homestead property with an intact homestead residence in the County. (See “Homesteading in Orange County” historic context below.) As mentioned above, the only other dwelling with a now distant association with homesteading in Orange County is James Shrewsbury’s home located on Eagle Rock Way.13 However, due to modern alterations and its relocation from the original homestead site, the Shrewsbury house does not 11 National Park Service, “National Register Bulletin 15:

How to Apply the National Register Criteria for
Evaluation,” 1990; revised 1991, 1995, 1997. Revised for Internet 1997, 9.
12 “Historic American Landscape Survey Laguna Beach
(HALS-CAL 123),” 19.
13 Smith, [letter dated September 18, 2025, Re. Agenda
Item 5.9, Design Review 24-0658, Coastal Development
Permit 24-0657].
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 6 retain sufficient integrity to be listed in the CRHR or NRHP. e) Integrity of Setting – In response to the issue of compromised integrity of setting, it is important to note that a historic property need not meet all seven aspects of integrity to be eligible for listing in the CRHR or the NRHP but should retain enough integrity to communicate its historic significance in relation to its physical environment. According to National Register Bulletin 15, “The evaluation of integrity is sometimes a subjective judgment, but it must always be grounded in an understanding of a property’s physical features and how they relate to its significance. …Ultimately, the question of integrity is answered by whether or not the property retains the identity for which it is significant.”14 In addition, the California Office of Historic Preservation Technical Assistance Series #6 notes, “It is possible that historical resources may not retain sufficient integrity to meet the criteria for listing in the National Register, but they may still be eligible for listing in the California Register. A resource that has lost its historic character or appearance may still have sufficient integrity for the California Register if it maintains the potential to yield significant scientific or historical information or specific data.”15
Historian Pat H. Stein, in research for the Arizona State Historic Preservation Office, provides guidance as it relates to the assessment of integrity of setting when evaluating homestead properties, as follows:

The essential thing to note in appraising location of setting for a homestead is the extent to which post-historic civilization has encroached on the rural character of the property. To take an extreme case: if the buildings and structures of what was once a 40-acre homestead are now tightly sandwiched amid “Strip” development, then the homestead has lost its integrity of setting. This is not to say that the homestead need retain all 40 acres in an undeveloped state in order for it to possess this type of integrity. However, enough of a visual buffer must exist around the old structures and buildings to still convey a sense of the historic surroundings.16
In the case of the Egan Homestead, although the immediate surrounding area has been developed as a residential neighborhood, the majority (more than 50%) of the Egan Homestead land has been retained as a wildlife conservation area in perpetuity, part of the Aliso and Woods Canyon Wilderness Area.

The HALS documentation affirms:

Ranch boundaries and the constraints posed by local hillsides and canyons 14 “National Register Bulletin 15: How to Apply the
National Register Criteria for Evaluation,” 44-45.
15 “California Office of Historic Preservation Technical Assistance Series #6 California Register and National
Register: A Comparison,” Office of Historic Preservation, Department of Parks and Recreation, California Register (California Code of Regulations, Title 14, Chapter 11.5, Section 4850 et seq), http://ohp.parks.ca.gov, accessed March 2026.
16 Pat H. Stein, “Homesteading in Arizona, 1870-1942,”
Arizona State Historic Preservation Office, 1990, 22-23. 629
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 7 discouraged or precluded development and created the opportunity for the conservation of the large areas of preserved open space. What is now known as the Laguna Greenbelt encompasses some 22,000 acres within and outside of the city limits and includes city-owned open space parcels, Laguna Coast Wilderness Park, Crystal Cove State Park, and Aliso and Wood Canyons Wilderness Park. Approximately 400 acres of privately owned land remain in naturally vegetated open space on the edge of urban development, mostly adjacent to publicly owned open space lands.17 This wildlife conservation area has retained the same characteristics as the rugged terrain present during the arrival of the Egan family ca. 1910.

Left: 1938 aerial photograph of the Egan Homestead, UC Santa Barbara Library. Right: 2024 aerial photograph of the Egan Homestead, Google Earth.

While there are some concessions for homestead properties provided by the National Park Service and other regulatory bodies as noted above, HRG acknowledged the property had diminished integrity of setting; however, the property still retains enough integrity of materials, design, workmanship, location, feeling, and association and still retains its essential form and appearance from its period of significance (historic identity) and therefore its association with homesteading in Orange County.

The paragraphs below are clipped from pg. 8 under Item 5 of GPA’s Peer Review:

5. Lastly, we assess whether the consultant’s conclusions are well reasoned, factually supported, and internally consistent, and we provide recommendations for improvement in future submittals when applicable.

Based on our review of the two independent historic resource assessments prepared by qualified professionals, GPA does not find sufficient evidence to support that the property at 31526 Valido Road meets the eligibility criteria for listing in either the California 17 “Historic American Landscape Survey Laguna Beach
(HALS-CAL 123),” 20.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 8 Register of Historical Resources or the National Register of Historic Places. As such, the property does not meet the definition of a “historical resource” under CEQA, nor does it appear to qualify as a historic resource under the City of Laguna Beach’s current Historic Preservation Ordinance, which requires that properties be either formally listed, eligible for listing, or voluntarily nominated by the property owner.

While HRG identified a potential association with early homesteading, the broader historic context presented does not convincingly support eligibility under Criterion 1, particularly in light of the compromised integrity of setting and the lack of rarity or comparative analysis. That said, GPA acknowledges there may be some potential for local historical significance under a more narrowly defined sub-context of early rural residential development in South Laguna, particularly given that the Egan residence is documented as one of the first homes constructed in the area. However, under the City's current ordinance—which requires owner consent for local designation—the property cannot be formally recognized unless the owner voluntarily elects to pursue local listing. Should the owner wish to do so in the future, the potential eligibility of the property under local criteria may warrant further exploration within this refined context.

HRG response:

Refer to response (d) and (e), above, for comments on comparative analysis and integrity of setting, respectively. See “Homesteading in Orange County” historic context below.

HOMESTEADING IN ORANGE COUNTY
Homesteads in California18
The Homestead Act in 1862 is perhaps the most sweeping piece of federal legislation passed in the nineteenth century in an effort by the federal government to encourage settlement through agricultural development west of the Mississippi River. It operated on the theory that “both Labor and rewards were distributed evenly through the population; permanent, responsible settlement resulted; families anchored people in space and through time; farm products provided an essential self-sufficiency; and an unlimited cycle of planting and harvesting ran no risk of depletion.”19 In actual practice, much work, investment, and luck proved necessary before even the relatively cheap federal or state lands yielded their first proceeds. Until that time, many homesteaders had to take out loans and live frugally in the hope that this American dream would eventually pay off.

Other legislation that enabled settlement of California’s federal and state agricultural lands included the Preemption Act of 1841; the Swampland Act of 1850; the Timber Culture Act of 1873; the Desert Land Act of 1877; the Enlarged Homestead Act of 1909; the Stock Raising Homestead Act of 1916.
18 The context for California homesteads is adapted from the California Department of Transportation, “A Historical Context and Archaeological Research Design for
Agricultural Properties in California,” 2007, 42-45.
19 Limerick, Legacy of Conquest, 124. As cited in “A
Historical Context and Archaeological Research Design for Agricultural Properties in California,” 43.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 9 Historians, William W. Robinson and Stan Stein examine the effects of federal homesteading laws and their influence on the broad patterns of rural agrarian life in the West.20 The data in Table 1 shows the number of total homestead claims granted in California. The proportion of claims and claimed acreage to all California agricultural properties differs markedly from other western and midwestern states. By 1900, homestead entries stabilized at just under half of all farm and ranch properties. The low proportion of entries reflects substantial consolidations of agricultural land because of prior Mexican and Spanish land grants, fraudulent federal and state land claims, and sections of land deeded to railroads as enticements to develop transportation systems to serve the state.

The acreage claimed by homesteaders continued to rise until it made up about a third of all agricultural land by 1940. That ratio is deceptive, however, because residual federal lands poorly suited for agriculture characterized most twentieth century claims. In addition, abandoned and rejected claims rose greatly after the turn of the twentieth century. For example, many Desert Land Entries were never “proven up” due to inadequate water and harsh conditions.

Table 1:Federal Land Records, California by County. California Department of Transportation, “A Historical Context and Archaeological Research Design for Agricultural Properties in California,” 2007. 20 William W. Robinson, Land in California, (Berkeley, CA:

University of California Press, 1979); Pat H. Stein,
Homesteading in Arizona, 1862 to 1940: A Guide to
Studying, Evaluating, and Preserving Historic Homesteads, (State Historic Preservation Office, Arizona State Parks, 1990). As cited in “A Historical Context and Archaeological Research Design for Agricultural Properties in California,”

42. 632
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 10 Professor Marshall Bowen recognized at least four distinct motivations for establishing homesteads in Nevada, which seem to mirror homesteads in California.21 Claimants included those wishing to establish farms, settlers who wanted to enlarge their existing holdings, those who simply wanted a country estate, and land speculators. These differences clearly influenced land use, residency, and the types of development strategies employed. Fabricated claims, however, were most likely among speculators and claimants adding acreage to an existing holding, not those with a bona fide interest in establishing a homestead.

Ultimately, the hard realities of the arid West, shortages of labor, costs of transporting crops to market, and depressed wholesale prices forced many aspiring western farmers to abandon their homesteads. Lands available for homesteading also became increasingly marginal over time, requiring ever-larger tracts to achieve success. As Gilbert Fite observes, “for most farm operations the needed efficiency required larger units”.22 In California, large ranchos from the Mexican and Spanish eras and enormous holdings controlled by railroad barons led to a pattern of large-scale factory type farming that came to dominate the regional marketplace, displacing small farms.

Homesteads in Orange County
In Orange County, availability of federal land was extremely limited due the large, private Mexican landholdings in Southern California. Following Mexico’s independence from Spain in 1821, the Californios became the region’s ruling class, many of whom were first generation descendants of the Portola expedition.23 Pio Pico, the last Mexican Governor of California, ordered all the Missions secularized in 1834, and soon began awarding generous land grants to prominent businessmen, officials, and military leaders.24 After the Mexican American War ended in the Treaty of Guadalupe Hidalgo in 1848, California officially became the thirty-first state in the Union on September 9, 1850. Facing growing political pressure to make lands in the West available for settlement by Americans, in 1851, the United States Congress passed the California Land Act – officially known as “An Act to Ascertain and Settle Private Land Claims in the State of California.” The statute established a three-member board known as the Public Land Commission, which was charged with determining the validity – or lack thereof – of land grants previously assigned by both the Mexican and Spanish authorities under earlier periods of rule. All holders of Spanish or Mexican land grants were required to present their titles for verification by the Public Land Commission.

Landowners were given two years to present sufficient evidence to support their claim to their land; if they could not do so, the property would automatically pass into the public domain and could then be dispensed by the United States government.25 The map in Figure 1 shows the distribution of California ranchos in Orange County in 1889. The limited portions of federal land open to homesteading was restricted to the Santa Ana 21 M. Bowen, “The Desert Homestead as a Non-Farm
Residence.” Nevada Historical Society Quarterly 31, no. 3 (1988): 198-211. As cited in “A Historical Context and
Archaeological Research Design for Agricultural Properties in California,” 44.
22 Fite, The Farmer’s Frontier, 238. As cited in “A Historical Context and Archaeological Research Design for
Agricultural Properties in California,” 45.
23 “Camp Pendleton Base History.” Camp Pendleton
website, www.cpp.usmc.mil. As cited in Historic Resources Group, “Historic Resources Survey Update, San
Clemente,” City of San Clemente, 2006, 21.
24 “Historic Resources Survey Update, San Clemente,” 21. 25 Historic Resources Group, “City of Pasadena’s Historic Context Statement,” City of Pasadena, 2025, 59.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 11 mountain range, the southern San Joaquin foothills, the area of Laguna Hills, and San Juan Capistrano.

Figure 1: Map of Orange County, 1889. Orange County Archives.

The largest landowner in the late nineteenth century in Orange County was James Irvine. Irvine immigrated from Belfast in 1845 and arrived in California during the Gold Rush. Although he mined for gold, Irvine found more success as a merchant selling produce and invested those profits into San Francisco real estate.26 During the drought of 1864, many Mexican landholdings in what was then southern Los Angeles County, were put up for sale due to financial loss in agriculture and cattle.27 It was during this time that Irvine, in partnership with businessmen 26 “Josh Sides, Backcountry Ghosts: California Homesteads and the Making of a Dubious Dream (University of
Nebraska Press, 2021), e-book, 206.
27 Clara Mason Fox, A History of El Toro (El Toro Women’s Club, 1940), 27.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 12 Llewellyn Bixby and Benjamin and Thomas Flint, acquired 110,000 acres of former ranchos, including the 47,000-acre Rancho Lomas de Santiago, 13,000 acres of the former Rancho Santiago de Santa Ana, and the 50,000-acre Rancho San Joaquin.28 The total acreage of their holdings amounted to approximately one-third of the entire county.

Between the Mexican land grants, private landlords like James Irvine, and the Southern Pacific railroad holdings, most Orange County homesteaders, approximately 70 successful in total,29 were forced primarily into the steep and rugged lands of the Santa Ana Mountains30 and the southern San Joaquin foothills, now Laguna Beach.31 The area of San Juan Capistrano was open to homesteading but limited in scope due to the establishment of the town of San Juan Capistrano following secularization of the Missions.32 Because the Southern Pacific railroad (SPRR) owned alternating sections of land given to them by the government as a subsidy to help build new railroad lines in California, settlers were left with two choices, to buy land from the railroad or to homestead federal land.33
Homesteads in the Santa Ana Mountains
The first settlers began arriving in the Santa Ana Mountains in the 1860s. The Bureau of Land Management (BLM) and local history records indicate early homesteads were established in Silverado Canyon (originally known as Madera Canyon), Santiago Canyon, Trabuco Canyon, Hall Canyon, San Juan Canyon, among other branches in the Santa Ana mountain range. Given the rugged terrain of the canyons, the main source of agriculture was limited to apiaries and some livestock.

In accordance with Homestead Act, early homesteaders in the Santa Ana Mountains turned to beekeeping as an agricultural form of “proving up” their homestead. Beekeeping (apiary) was one of the most important industries in the Santa Ana Mountains in the late nineteenth and early twentieth centuries. The bees fed on (and pollinated) every flowering plant that grew in the hills, predominately in the spring and early summer, though there was always pollen available year-round. Honey was harvested while bees were out foraging. The honey was stored in drums, some holding as much as 1,500 pounds. Two men could fill one drum in a day during the height of the harvest, with 180 pounds a year per hive being considered a good yield. The honey crop for Southern California was estimated at three million pounds in the early 1880s.

The returns were low (only 4-5¢ a pound), but it was a dependable cash crop for many canyon homesteaders.34 Few cattle and goats were tended in the area.35 Samuel Shrewsbury (1838-1901), oldest brother of James M. Shrewsbury, arrived in Silverado Canyon ca. 1860 and laid claim to 134 acres, receiving his land patent in 1878.36 Prior to this claim, Shrewsbury had filed a claim on Saddleback ridge between Modjeska and Santiago peaks. 28 Backcountry Ghosts, 206.
29 Backcountry Ghosts, 212.
30 The Santa Ana Mountain range spans approximately 60
miles along the northeast border of Orange County and
Riverside County.
31 A History of El Toro, 29.
32 “The Town of San Juan Capistrano,” OC Historyland,
https://www.ochistoryland.com, accessed March 2026.
33 “Trabuco Oaks – A Canyon Community,” OC
Historyland, https://www.ochistoryland.com, accessed
March 2026.
34 “Trabuco Oaks – A Canyon Community.”
35 A History of El Toro, 30.
36 Samuel Shrewsbury (Orange, CA), homestead patent no. 531, “Land Patent Search,” General Land Office Records, accessed March 2026,
https://glorecords.blm.gov/details/patent/default.aspx?acc ession=CA0500__.438&docClass=STA&sid=ikbsm1px.ipi#p
atentDetailsTabIndex=0.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 13 There he established a homestead near his friend, J. Edward Pleasants. Shrewsbury established his homestead on the south slope where the canyon widened in the fertile valley. Here he set up a lime kiln to produce and sell quicklime in Los Angeles, as well as an apiary, supported by wildflowers and a natural spring. He built a two-bedroom dwelling and planted a fruit and nut tree orchard and a large grape arbor. The arbor became an attraction of the Shrewsbury homestead, welcoming many guests including Madame Modjeska.37 The Pleasants relocated to Silverado Canyon and acquired a 160-acre homestead south of the Shrewsbury property.38 A few years later, Count Karol Bozenta Chlapowski and Madame Helena Modjeska, Russian actress and socialite, bought the Shrewsbury homestead, the Pleasants’ ranch, a part of the Serrano acreage, and some adjoining railroad land. The couple improved the 1,300-acre estate, named Arden, with several buildings, including the single-story Modjeska House, a Queen Anne style cottage designed by architect Stanford White. The cottage incorporated the original cabin home built by the Pleasants in the 1890s.39 The estate was listed in the National Register of Historic Places in 1990, significant for its association with Madame Helena Modjeska. The current 14-acre estate is now an Orange County Historical Site. Neither the Shrewsbury nor the Pleasants homesteads are extant.

Typical bee ranch in the Santa Ana Mountains, Modjeska House, ca. 1980. (Orange County Archives) ca. 1914. (Orange County Public Library)
The Mason family arrived in Silverado Canyon in 1887 from Illinois and laid claim to 120 acres below the Shrewsbury property.40 The Mason family ultimately discovered a sulfur spring on their homestead, leading them to improve the property and convert it into a resort with healing waters called Mason’s Chateau.41 The Mason homestead is no longer extant.

The Masons youngest daughter, Clara Mason Fox (1873-1959) acquired a claim below her family’s property and lived on it for a year before turning it over to her brother Charles S. Mason when she relocated to New York to attend Cooper Union College in 1896.42 Clara was an 37 McClelland, “Silverado Canyon Sketches,” 39.
38 J. Edward Pleasants (Orange, CA), homestead patent no. 446, “Land Patent Search,” General Land Office Records, https://glorecords.blm.gov/, accessed March 2026.
39 James H. Charleton, “National Register Nomination:

Forest of Arden” National Park Service, 1990, 3.
40 Nancy L. Mason (Orange County, CA), homestead
patent no. 2767, “Land Patent Search,” General Land
Office Records, https://glorecords.blm.gov/, accessed
March 2026.
41 McClelland, “Silverado Canyon Sketches,” 55.
42 McClelland, “Silverado Canyon Sketches,” 53.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 14 educated woman and became Silverado’s first schoolteacher and an early Laguna Beach artist.43 After a year, she returned to Silverado to continue teaching. In 1906, she married George Kirby Fox (1874-1951). The couple settled in Laguna Beach about 1920, where she designed a Craftsman bungalow as their family home. Later, they relocated to El Toro and built a two-story farmhouse.44 In 1937, Clara was commissioned by the El Toro Women’s Club to write A History of El Toro, published in 1940. As an educator, poet, historian, and artist, Clara is best known for her delicate and detailed botanical watercolors of the flora of Silverado Canyon and the surrounding area, located at the California Botanical Gardens.45 In her history of El Toro, Clara Mason Fox notes other early homesteaders in branches of the San Juan Canyon, including Samuel T. Miller and Josiah C. Joplin in Belle Canyon.46 Miller homesteaded 138 acres in Belle Canyon in 1873. He built a cabin and resided there for twentyone years until receiving a land grant in 1894.47 Miller created a successful business as an apiarist on his homestead, ultimately relocating to Santa Ana.48 Both the Miller and Joplin homesteads are no longer extant.

The Adkinson family lead by patriarch Jesse Adkinson relocated to Trabuco Canyon in 1883, after a failed attempt to homestead land between ranchos Santiago de Santa Ana and Las Bolsas in what is now Fountain Valley.49 Adkinson settled in the Trabuco Oaks area where he lived until his death in 1926. His sons, Jesse Jr. and W.E. (Ed) Adkinson, acquired homestead claims from early pioneer N.T. (Tule) Wood, and developed a ranch in the canyon.50 The Adkinsons were prominent canyon residents for decades. The Adkinson ranch farmhouse is no longer extant.

W.E. Adkinson farmhouse, Trubaco Canyon, 1946. Not extant. (Orange County Archives)
43 “May 2013 Meeting – Program: Clara Mason Fox, O.C.

Pioneer – Speaker: Lorraine Passero,” Orange County
Historical Society, https://www.orangecountyhistory.org/, accessed March 2026.
44 Fullerton Heritage, [One of the first pioneering female artists of Orange County], Facebook, April 29, 2025,
https://www.facebook.com/FullertonHeritageOC/.
45 [One of the first pioneering female artists of Orange County].
46 A History of El Toro, 30.
47 Samuel T. Miller (Orange County, CA), homestead
patent no. 2091, “Land Patent Search,” General Land
Office Records, https://glorecords.blm.gov/, accessed
March 2026.
48 Samuel Armor, History of Orange County with
Biographical Sketches (Historic Record Company, 1921),
773.
49 “Trabuco Oaks – A Canyon Community.”
50 A History of El Toro, 31.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 15 Other settlers in Trabuco Canyon included Jim Brown and Lew English, who acquired claims later purchased by Walter K. Robinson in 1883, which he developed into a 1,260-acre ranch called Mountain View Ranch.51 Robinson was born in Santa Clara in 1853. He married Margaret Waite of Los Angeles in 1883. For many years, Robinson held the office of Deputy Fish and Game Commissioner of California, with headquarters in Trabuco Canyon. Robinson planted 30 acres of vineyards and an orchard, 300 acres of barley, and he pastured the rest of the land, raising racehorses as well as Berkshire hogs and Jersey cattle. Water was hauled from Medlin Spring on the upper part of the ranch.52 The Robinson house was originally built as a singleroom cabin in 1883 by original homesteader Jim Brown. Over the years, the house underwent several additions.53 Robinson died in 1920; he was honored as one who remained through days of adversity and who never desired to live elsewhere.54 The Robinson ranch house was demolished in 1988.

Philander W. Straw and his family settled in Live Oak Canyon around 1878 on a 158-acre homestead.55 Straw (1831-1899), a Civil War veteran, came seeking a drier, healthier climate.

Like several early canyon residents, Straw was primarily an apiarist. He built a two-story home and several outbuildings on his homestead, which are no longer extant. P.W. Straw’s son Gus (1877-1959) took over the ranch after his father’s death and added to it, buying an adjoining 80- acres to the northwest. Gus Straw ran cattle, raised pigs, and kept bees. Much of the 158-acre Straw homestead is now a part of O’Neill Regional Park in eastern Orange County.56

Walter K. Robinson ranch house, 1988. Not extant. The Straw homestead, ca. 1900s. Not extant. (Doug McIntosh via OC History Roundup) (Orange County Archives) In 1902 Gus Straw married Trabuco schoolteacher Pearl Gray. They built a new house just south of his parents’ place. He continued to run cattle on the ranch until 1941 when he and his brother Herbert sold most of the property (300 acres). Gus Straw held on to the house and a little land around it but resided predominately in Laguna Beach. After his wife died in 1952, Straw sold his last eleven acres to Andrew Hoffman. Thus, Straw’s old home site is today marked on maps as the “Hoffman Homestead” in the O’Neill Regional Park.57 Hoffman enlarged 51 A History of El Toro, 31.
52 A History of El Toro, 31.
53 “Robinson Ranch.” Note: The Robinson Home's cobble
fireplace and a few other architectural features were
salvaged from demolition and incorporated into the homeowners association community center/swimming pool area.
54 The Santa Ana Register, Nov. 12, 1920, as cited in
“Robinson Ranch.”
55 Philander W. Straw (Orange County, CA), homestead
patent no. 2083, “Land Patent Search,” General Land
Office Records, https://glorecords.blm.gov/, accessed
March 2026.
56 “Historic Spots in O’Neill Park,” OC Historyland,
https://www.ochistoryland.com/, accessed March 2026.
57 “Historic Spots in O’Neill Park.”
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 16 and lived in the house for over twenty years until declining health forced him to move out. The park acquired the property in 1974, and the house was later demolished.58 Only the remains of one of Gus Straw’s cattle pens can still be seen at the northern end of the park.

The Gus Straw home site ca. 1974, showing the additions (left) built by Andrew Hoffman. Not extant. (Doug McIntosh via OC Historyland) Beginning in 1890, the whole Santa Ana Mountain range was surveyed by the government for the establishment of the Cleveland National Forest in 1893, and only those with legal claims could remain within the boundaries of the forest.59 The railroads seized all the alternate sections they could as “lieu-lands” from the Black Star Canyon up to the Hughes (Holtz) boundary.

Figure 2: Trabuco Ranger District – Cleveland National Forest.

Forest Service, United States Department of Agriculture. 58 “Historic Spots in O’Neill Park.”
59 For more information on the development of the
Cleveland National Forest, refer to “Discover History,” Forest Service US Department of Agriculture,
https://www.fs.usda.gov/, accessed March 2026.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 17 Carla Mason Fox notes in her history of El Toro that by 1900, the Santa Ana mountain range settlement was well established, with most settlers raising bees, some stock, fruit trees, and vineyards.60 However, due to development limitations put in place by the Cleaveland National Forest, these early settlements did not ultimately thrive and were later sold or abandoned.

Others were sold as public land and incorporated into the Orange County Regional Park system, including O’Neill Regional Park, Whiting Ranch Wilderness Park, the Limestone Canyon Nature Preserve, among other designated wildlife preserves in the area. As a result, HRG did not find any homestead properties with original surviving residences in the Santa Ana mountain range.

Homesteads in Laguna Beach
Out by the coast, the land in the southern San Joaquin foothills was open to homesteading.

According to Merle and Mabel Ramsey in The First 100 Years in Laguna Beach (1876-1976), when California Governor Juan B. Alvarado granted Rancho San Joaquin (now Irvine Ranch), to Jose Sepulveda and Rancho Niguel to Juan Avila in 1842, the land between the two grants west to the ocean was not included. Ramsey’s research revealed that the land was inhabited by the Acunna family and Ysidoro Olivaries with his two sons. There is no date as to their arrival. The Acunnas later migrated to EI Toro. Olivaries worked for seventy years on the Rawson Ranch (later the Moulton Ranch) and broke horses until he was 90. During this time, he built a home and homesteaded fifty acres (not surveyed) between the Irvine and the Moulton ranches. Born in San Diego in 1826, Ysidoro Olivaries died in 1933 at the age of 107 in the Orange County Hospital. He left his land to the Daguerre family, which later became Leisure World-Laguna Hills.61 No structures are extant from the Olivaries homestead.

The “no grant” public lands that would become Laguna Beach were surveyed beginning in 1855, and in 1875 one surveyor noted the triangle of land between the ranchos had very little value because of its rocky terrain and salty springs. Beginning in 1875, several families from the midwest laid claims to those federal lands in Laguna Beach. The Goffs, Rogers, Thurstons, Nathan and William Brooks, and the Egan and Shrewsbury families, among other individuals. There were forty-two homestead claims between 1875 and 1916.62 In accordance with the Timber Culture Act of 1873, many of Laguna’s first families planted groves of eucalyptus trees on their homesteads to meet the homesteading criteria of the Act and “prove-up” their claim. The trees grew quickly and thrived in Laguna’s climate and soon became the preferred tree homesteaders used as wind breaks. Before long, most of the settlement was dotted with Australian eucalyptus trees.63
In 1878, John Damron claimed a 155½ acre homestead in Laguna Canyon, through what is now downtown Laguna Beach and down to Main Beach.64 In 1879, he sold the land to brothers Cyrus and Hiram Rawson before ever making any improvements. Two years later, the Rawsons sold the claim to George Rogers and his father, Henry Rogers, for $1,000.65 In 1878, Henry Rogers claimed an additional 160 acres which stretched from Temple Hills to Bluebird Canyon. To 60 A History of El Toro, 31.
61 Gene Felder, “How the Settlers Homesteaded in
Laguna,” The Los Angeles Times, January 23, 2004; Merle and Mabel Ramsey, The First 100 Years in Laguna Beach
1876-1976 (Laguna Beach Historical Society, 1976), 4-5. 62 Beryl Wilson Viebeck, Laguna Beach Homesteaders
1875-1916, Map, Laguna Beach Historical Society.
63 “Laguna’s Hidden History: The Trees of Forest Avenue,” Visit Laguna Beach, https://www.visitlagunabeach.com/,
accessed October 2025.
64 “Homesteaders Henry and George Rogers,” Laguna Life
(The Laguna Beach Historical Society Newsletter), April 2014, accessed October 2025.
65 “Laguna’s Hidden History: The Trees of Forest Avenue.” 640
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 18 prove-up the homestead and increase their holdings, Henry and George planted Australian Eucalyptus trees throughout their land.66
George Rogers and his family settled in downtown Laguna, building a ranch house (not extant) and planting a large pepper tree where Laguna City Hall now stands on Forest Avenue. In 1887, George began subdividing the downtown area into small lots, as part of the city’s first subdivision, named Roger’s Addition.67 He also named several streets in downtown Laguna such as Forest Avenue and Ocean Avenue. Because of failing health, George Rogers sold much of his land to his niece, Ora H. Wayman (Warling) in 1896 before returning to Kirksville, Missouri.68

George Rogers ranch house, ca. 1926. Not extant. (First Main Beach featuring Nate Brooks house on the left, date American Title Co., Orange County Historical Photo Archive) unknown. Not extant. (Laguna Beach Historical Society) A large portion of Arch Beach was homesteaded by brothers William and Nathaniel “Nate” Brooks, who arrived at Woods Cove in 1876. William’s wife, Annie H. Brooks, named the area Arch Beach after a natural rock formation near the end of Pearl Steet.69 Nate Brooks brought water to Arch Beach down from Bluebird Canyon through a 500 foot tunnel and developed a dirt wagon road to the village of Laguna Beach, which was platted in 1883 by Henry E. Goff.70 Nate received two land grants in Arch Beach – one in 1897 for 157 acres71 in the vicinity of Woods Cove and another in 1894 for 163 acres72 in lower Bluebird Canyon. William received a land grant for 169 acres in 1889 in the area of Arch Beach Heights.73 This large central area of Laguna Beach was subdivided and developed beginning in the early 1920s.

The Goff family arrived in Laguna Beach in 1878. There were four brothers who acquired homestead claims between downtown Laguna Beach to Aliso Canyon – Frank, Henry, Lee, and Hubbard Goff.74 Henry Goff’s 51.4 acre homestead south of what is now Park Avenue, was 66 “Laguna’s Hidden History: The Trees of Forest Avenue.” 67 “Homesteaders Henry and George Rogers,” Laguna Life
(The Laguna Beach Historical Society Newsletter).
68 “Old Rancho New Clubhouse,” Long Beach PressTelegram, April 17, 1927 69 Chris Jepsen, “Arch Beach Won’t Stay Put,” O.C History Roundup, published September 1, 2021,
https://ochistorical.blogspot.com/, accessed March 2026. 70 “History of Laguna Beach,” Orange County Historical
Society, https://www.orangecountyhistory.org/, accessed January 2026.
71 Certificate no. 624 for Lorenzo N. Brooks, March 13, 1897, US Department of the Interior, Bureau of Land
Management, https://glorecords.blm.gov/, accessed
February 2026.
72 Timber-Culture Certificate No. 51 for Lorenzo N.

Brooks, April 27, 1894, US Department of the Interior,
Bureau of Land Management, https://glorecords.blm.gov/, accessed February 2026.
73 Certificate no. 2190 for William H. Brooks, January 12, 1889, US Department of the Interior, Bureau of Land
Management, https://glorecords.blm.gov/, accessed
February 2026.
74 “History of Laguna Beach,” Orange County Historical
Society, https://www.orangecountyhistory.org/, accessed January 2026.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 19 recorded in 1880. When the area was subdivided in 1883, Laguna Avenue was named, designating the route to the large site Goff had reserved for what became the Hotel Laguna.75 The tract, along with Roger’s homestead to the west, now comprise downtown Laguna Beach.

In 1871, Eugene Salter was the first American settler in South Laguna. He claimed 152 acres of Aliso Canyon. After he left, George and Sarah Thurston claimed his land with a one-room cabin in 1879.76 The claim included steep hillsides, a meandering creek bed, and land near the shore, not traditionally suitable for farming. The Thurstons managed to grow crops and established a farm, raising chickens and cows (for eggs and butter), and an apiary. They also grew grapes, walnuts, and watermelons.77 George Thurston ultimately left the family, and his son, Joe Thurston, stepped in to support his mother, Sarah. Joe Thurston left the homestead in 1921, after purchasing it from Sarah Thurston who relocated to Santa Ana, where she died in 1928.78 Joe Thurston also purchased the George Rogers homestead, developing the Temple Hills tract in 1926,79 and became deeply involved in the development of Laguna Beach. The Thurston homestead in Aliso Canyon is no longer extant.

Thurston homestead in Aliso Canyon, ca. 1920. Not extant. (Laguna Beach Historical Society)
Other early homesteaders in South Laguna include Leon W. Goff, Sr. in 1884, Layette Thurston and George Thurston, Jr. in 1891, and William F. Egan and James M. Shrewsbury in 1910 and 1911.80 These homesteaders claimed land from Aliso Canyon south to Three Arch Bay. In central South Laguna, Blanche L. Dolph and Priestly Hall acquired Leon W. Goff’s 153-acre claim of coastal land for $700 in 1903.81 Just north of Blanche Dolph’s property, William Egan and his uncle, James Shrewsbury, took up separate claims totaling 200 acres of land extending from approximately West Street to Tenth Avenue.82 Egan built two of the first three residences in South Laguna, the Egan home at 31526 Valido Road ca. 1910, and the Shrewsbury home at the 75 City of Laguna Beach, “Laguna Beach Landscape and
Scenic Highways Resource Document,” Adopted
November 13, 2018, 66.
76 Turnbull, “A Short History of Laguna Beach.”
77 “Joseph Thuston's Laguna Beach of Early Days,” OC
Historyland, accessed March 2026.
78 “Joseph Thuston's Laguna Beach of Early Days.”
79 Tract No. 503, Temple Hills Map, Orange County
Assessor, 1926, Orange County Public Works, accessed
March 2026.
80 Beryl Wilson Viebeck, Homestead Map Overlays
Modern Streets, Laguna Beach Historical Society.
81 “Soars Does Land On Beach,” The Los Angeles Times,
August 8, 1906; J.S. Thurston, “Laguna Beach: Early Days,” (The History Press: Charleston), 1947.
82 US Department Bureau of Land Management, Patent
#027766 for 40 acres granted to William F. Egan, Issue
Date 1/17/1910; US Department Bureau of Land
Management, Patent #170682 for 160 acres granted to
James M. Shrewsbury, Issue Date 1/16/1911.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Peer Review Response 20 north end of Third Avenue.83 Together, Egan and Shrewsbury farmed the land, and grew melons, string beans, lima beans, and squash to sell at markets in Los Angeles and San Francisco.84 Egan and Shrewsbury succeeded in making their homesteads profitable and secured their claims. The Egan residence survives on Valido Road, while the Shrewsbury residence was moved in the 1930s (to Eagle Rock Way) and significantly altered.85
Egan homestead, ca.1910. (Nancy Burnham and Deborrah Shrewsbury homstead, ca. 1915. (First American Title Co.

Allen in memory of Howard Russel Hind and Esther Egan Orange County Historical Photo Archive) Hind; the South Laguna Civic Association)
The early homesteads in Laguna Beach, unlike the homesteads in the Santa Ana Mountains, were ultimately developed and subdivided into commercial and residential neighborhoods between the areas of downtown Laguna Beach through Arch Beach to South Laguna (previously Three Arches). The City of Laguna Beach was incorporated in 1927, and Three Arches was renamed South Laguna in 1934, which was later annexed in 1987. The City of Laguna Beach underwent several periods of development, first in the 1880s, then in the 1920s, followed by the postwar period, and then in the 1980s. Over time, the early homestead dwellings were overtaken by development, demolished, or relocated and significantly modified, like the Shrewsbury home. The Eagan Homestead residence was eventually integrated into the surrounding neighborhood; however, it was never demolished or significantly altered and remarkably retains its appearance from its period of significance (historic identity). It is the last remaining homestead dwelling in its original location and is representative of early twentieth century homesteads, not only in Laguna Beach but also in Orange County. 83 Karen Wilson Turnbull, “Three Arch Bay: An Illustrated History,” (Friss-Pioneer Press: Santa Ana), 1977, 35.
84 “50 Cents Pound Received For Early Beans,” The Santa Ana Register, April 10, 1920.
85 Francesca Smith, [letter dated September 18, 2025, Re.

Agenda Item 5.9, Design Review 24-0658, Coastal
Development Permit 24-0657,] City of Laguna Beach
Notice of Appeal for 31526 Valido Road, October 8, 2025. 643
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April 5, 2026
Heather Steven
Senior Planner
Community Development Department
505 Forest Avenue
Laguna Beach, CA 92651
(949) 497-0332
Via e-mail: [email protected]
Re: Second Peer Review – 31526 Valido Road, Laguna Beach, California Dear Ms. Steven:

GPA Consulting (GPA) previously prepared a peer review of historic resource assessment reports for the property located at 31526 Valido Road in Laguna Beach, California. The initial assessment, prepared by Historic Resources Group (HRG) on behalf of the City, concluded that the property qualifies for listing in the California Register of Historical Resources (CRHR) under Criterion 1 due to its association with early homesteading and the Homestead Act of 1862. In response, the applicant retained Chronicle Heritage, which prepared a separate historic resource assessment concluding that the property does not qualify for listing due to insufficient integrity, particularly with respect to setting.

Due to these conflicting conclusions, the City engaged GPA to provide an independent, third-party peer review to evaluate whether the conclusions presented in the HRG report were adequately supported by the facts. GPA completed this initial peer review in July 2025, based on the following documents:
• Historic Resources Assessment, 31526 Valido Road, Laguna Beach (Historic Resources Group, February 12, 2025)
• Historic Assessment Supplemental Memorandum (Historic Resources Group, June 3, 2025) • Historic Resource Assessment of 31526 Valido Road, Laguna Beach 92651 (Chronicle Heritage, April 2025)
Subsequent to GPA’s initial peer review, the applicant’s request to demolish the existing residence and construct a new single-family dwelling was approved by the Design Review Board on September 25, 2025. That decision was appealed to the Laguna Beach City Council. In response to the appeal, additional materials were prepared and submitted to the City, including:
• Historic Resource Technical Memorandum (Environmental Science Associates [ESA], January 27, 2026)
• Response to Comments on Historic Resource Assessment (Historic Resources Group, March 23, 2026) In light of this expanded record, the City has requested that GPA conduct a second peer review of the newly submitted materials and prepare a memorandum with recommendations to City staff in advance of the appeal hearing. As part of this scope of work, GPA has reviewed the above-listed documents, in addition to public comments submitted in response to the proposed project, including correspondence from Ann Christoph, Landscape Architect, dated September 19, 2024, and correspondence from Greg O’Loughlin, President of the South Laguna Civic Association, dated July 24, 2022, which provide historical information and perspectives regarding the subject property. GPA’s review also incorporates the previously evaluated reports prepared by HRG and Chronicle Heritage.

Attachment 23
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GPA’s role in this process is to provide an objective, non-biased evaluation of the adequacy of each report, with particular focus on the methodology, accuracy, completeness, and evidentiary support for the conclusions presented. GPA has not conducted a new historic resource assessment, site visit, or independent research.

Rather, this peer review is limited to an evaluation of the existing record to determine which conclusions are most appropriately supported by substantial evidence in light of applicable professional standards, including guidance set forth in National Register Bulletin 15 and the California Environmental Quality Act (CEQA).

Summary of Environmental Science Associates (ESA) Technical Memorandum Environmental Science Associates (ESA) prepared a Historic Resource Technical Memorandum dated January 27, 2026, at the request of the property owner in response to the appeal of the Design Review Board’s approval of the proposed project. The memorandum includes a review of previously prepared historic resource assessments, including those by Historic Resources Group (HRG), Chronicle Heritage, and GPA’s prior peer review, as well as supplemental research utilizing archival sources such as historical aerials, property records, and regional historical documentation. ESA also conducted a site visit of the subject property on October 29, 2025. The evaluation was prepared by a qualified architectural historian in accordance with the Secretary of the Interior’s Professional Qualification Standards and applicable federal, state, and local regulatory frameworks, including the National Register of Historic Places (NRHP), the CRHR, and the City of Laguna Beach Historic Preservation Ordinance.

ESA concludes that the subject property does not meet the eligibility criteria for listing in the California Register of Historical Resources (CRHR) or the National Register of Historic Places (NRHP) and therefore does not qualify as a historical resource under CEQA. This conclusion is consistent with GPA’s prior peer review and is based on the determination that, while the property is associated with early homesteading activity, it does not rise to the level of significance required under applicable criteria. ESA further finds that the property does not retain sufficient integrity to convey its historical significance, particularly in light of changes to the surrounding context.

The memorandum also notes that the physical condition of the structure is poor and that rehabilitation for continued residential use would likely require substantial alterations that could affect remaining characterdefining features. While ESA acknowledges that the property may have some local historical interest as an early residence associated with rural development in South Laguna, it concludes that this does not meet the threshold for eligibility under the CRHR or NRHP criteria.

Although ESA determines that the property is not a historical resource under CEQA, the memorandum recommends several measures to document and interpret the site’s history, including preparation of Historic American Buildings Survey (HABS)-level documentation, installation of an interpretive historical marker, potential relocation of the original portion of the residence for interpretive purposes, and, if relocation is not feasible, the salvage and donation of character-defining materials. These recommendations are presented as measures to preserve historical information rather than as support for eligibility.

Summary of Historic Resources Group (HRG) Response to GPA Peer Review Historic Resources Group (HRG) prepared a Response to Peer Review Memorandum dated March 23, 2026, in response to GPA’s July 2025 peer review of the historic resource assessments for the property at 31526 Valido Road. The memorandum is focused on addressing GPA’s conclusion that insufficient evidence was presented to support eligibility of the subject property for listing in the CRHR or the NRHP. HRG does not dispute GPA’s findings regarding methodology or research adequacy, but instead challenges GPA’s interpretation of the evidence, particularly with respect to historic context, rarity, comparative analysis, and integrity.

In response, HRG presents additional research intended to strengthen its original conclusion that the property is eligible under CRHR Criterion 1 and NRHP Criterion A at the local level. HRG expands its historic context to include “Homesteading in Orange County,” providing broader regional background on land ownership patterns, settlement limitations, and the relative scarcity of successful homesteads due to the dominance of large private landholdings and railroad-controlled lands. Based on this expanded research, HRG asserts that the Egan Homestead is a rare resource, potentially representing the only surviving homestead residence in Orange County 645
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that retains integrity and association with its original use. HRG also responds to prior concerns regarding the lack of comparative analysis by arguing that comparable properties no longer exist or have been significantly altered or relocated and therefore do not retain sufficient integrity for meaningful comparison.

HRG further addresses the issue of integrity, acknowledging that the property has experienced a loss of historic setting but maintaining that sufficient integrity remains in other aspects, including location, design, materials, workmanship, feeling, and association. The response emphasizes that a property does not need to retain all seven aspects of integrity to be eligible and cites guidance supporting a flexible and context-driven evaluation of integrity. HRG also introduces the argument that adjacent preserved open space, including the Laguna Greenbelt and surrounding wilderness areas, provides a visual and environmental context that continues to convey aspects of the property’s historic setting despite surrounding residential development. In addition, HRG expands its discussion of the Homestead Act, emphasizing its long-term role in shaping settlement patterns in the American West and reinforcing the relevance of the property’s period of significance within this broader historical framework.

Based on this expanded analysis, HRG maintains that the subject property meets the eligibility criteria for listing in the CRHR and NRHP at the local level, asserting that its rarity, historical associations, and retained integrity collectively support its significance as a representative example of early homesteading in the region.

Summary of Public Comments
GPA reviewed public correspondence submitted to the City regarding the subject property, including letters from members of the public and local organizations.

A letter dated September 19, 2024, from Ann Christoph, a landscape architect, asserts that the residence was constructed in association with the Egan family’s 1910 homestead and characterizes the property as the oldest house in South Laguna and potentially the last remaining homestead residence in Laguna Beach. The letter expresses concern that the property’s potential historic significance was not clearly identified in project materials and supports further consideration of its historic status.

Additionally, correspondence dated July 24, 2022, from Greg O’Loughlin, President of the South Laguna Civic Association, describes the property as a historically significant homestead associated with early settlement patterns in South Laguna. The letter references the Egan family’s 40-acre homestead claim, early agricultural use of the site, and the property’s association with broader patterns of homesteading in the area. The correspondence asserts that the property may qualify as a historic resource and advocates for its preservation.

Peer Review Analysis – Environmental Science Associates (ESA) Environmental Science Associates’ (ESA) Historic Resource Technical Memorandum (January 27, 2026) provides a clear and professionally consistent evaluation of the subject property in accordance with applicable federal and state criteria and CEQA guidelines. ESA demonstrates a sound understanding of the distinction between historical association and historical significance and appropriately applies this framework in concluding that the property does not meet the eligibility threshold under Criterion A/1. The memorandum is generally consistent with GPA’s prior peer review, reinforcing the conclusion that association with early homesteading activity, without a clear demonstration of importance within a defined historic context, is insufficient to establish significance. ESA also appropriately recognizes that while the property may have local historical interest, this does not rise to the level required for listing in the CRHR or NRHP.

ESA’s conclusions regarding integrity are also generally consistent with prior findings, particularly with respect to the diminished integrity of setting and the resulting impact on the property’s ability to convey its historical associations. While ESA does not present a detailed, aspect-by-aspect integrity analysis, its conclusions align with the interpretation that the loss of the surrounding agricultural context limits the property’s ability to communicate its significance under Criterion A. The memorandum also introduces consideration of the current physical condition of the structure, noting that substantial rehabilitation would likely be required, which could 646
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