Alta Archaeological Consulting, LLC
2681 Cleveland Ave.
Santa Rosa, CA 95403
office (707) 544-4206
fax (707) 546-2135
www.altaac.com
May 8, 2026
Jonathan Lukoff
238 Chiquita Street
Laguna Beach, CA 92651
Re: 238 Chiquita, Laguna Beach (ADU - City Council Appeal) Introduction
The applicant proposes to construct an accessory dwelling unit (ADU) on the property located at 238 Chiquita Street (proposed project). The residence on the subject property is a designated historical resource afforded protections under the California Environmental Quality Act (CEQA) and is referred to hereafter as the historic house. Although the proposed project meets applicable state and Laguna Beach (City) requirements for ADUs, including zoning and building codes, the proposed project application was denied by the City’s Heritage Commission and Design Review Board over historic preservation concerns. The purpose of this memorandum is to respond to the concerns articulated in the Historic Resources Group (HRG) memo dated January 26, 2026 (Attachment 9),1 which is updated
from a memo prepared by HRG on July 12, 2023 (Attachment 8).2 The HRG memos indicate the proposed project does not meet the Standards for the Treatment of Historic Properties (Standards) 2, 4, and 9 of the Standards for the Treatment of Historic Properties: Rehabilitation (Standards). The purpose of this memorandum is to demonstrate the project meets the Standards and would not result in a significant impact or substantial adverse change to a historical resource as defined in Section 15064.5(b)(3) of the CEQA Guidelines.
Background
The subject property contains a single-family residence (historic house) constructed in 1925/26 by Nils Anderson as noted in both HRG memos. The historic house was identified as potentially significant in the City’s 1981 survey. The 2-story historic house is noted as a Craftsman Cottage of key significance (“K”) in the City’s Historic Register Index List, July 2024.3 Based upon a review of the
public record, a request for formal listing in the City’s historical register was submitted by Jonathon Lukoff on September 27, 2008, which indicates the subject property is significant for representing “Old Laguna.”4 Mr. Lukoff indicated that distinctive features included that the historic house is “one 1 Historic Resources Group, “238 Chiquita Street, Laguna Beach, Revised ADU Review,” City of Laguna Beach, January 26, 2026,
https://lagunabeachcity.primegov.com/Portal/Meeting?meetingTemplateId=768. 2 Historic Resources Group, “238 Chiquita Street, Laguna Beach Peer Review,” City of Laguna Beach, July 12, 2023,
https://lagunabeachcity.primegov.com/Portal/Meeting?meetingTemplateId=768. 3 City of Laguna Beach, “Historic Register Index, July 2024,” n.d., https://www.lagunabeachcity.net/home/showpublisheddocument/9102/638563011154330000. 4 https://portal.laserfiche.com/Portal/Browse.aspx?id=244295&repo=r-1645a77d
Alta Archaeological Consulting, LLC — 2681 Cleveland Avenue, Santa Rosa, CA 95403 www.altaac.com / office (707) 544-4206 / fax (707) 546-2135 of few home[s] set back but visible, looking older, but well maintained. Represents its era well.”5 The historic house was listed in the City’s Historic Register the same year.
The historic house was assigned a status of “K.” The City’s published Historic Properties Categories defines “K” or Key as buildings that are significant for architectural, historical, and/or aesthetic values.
The applicant entered into a Mills Act contract that was recorded with Orange County on August 22, 2012. Subsequent to execution of the Mills Act contract, the applicant constructed an addition to the historic house that was reviewed by the City’s historic preservation consultant and determined the proposed addition met the Standards.6
Definition of Setting
The Standards recognize historic properties are not meant to be frozen in time and provide a series of standards and guidelines to ensure alterations and new construction are designed and built in a sympathetic manner to minimize physical impacts but also impacts to a property’s setting.
Setting is one of the seven criteria to evaluate a property’s integrity, or a property’s ability to convey its significance.The How to Apply the National Register Criteria for Evaluation bulletin defines setting as:
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 placed its historical role. It involves how, not just where, the property is situated and its relationship to surrounding features and open space. …. These features and their relationships should be examined not only within the exact boundaries of the property, but also between the property and its surroundings. This is particularly important for districts. 7
Analysis
Standard 2: The historic character of a property shall be retained and preserved. The removal of historic materials or alteration of features and spaces that characterize a property shall be avoided.
The proposed project would not alter the existing historic house because no work is proposed.
Therefore, no historic materials or alteration of features will occur.
The property was constructed prior to incorporation of the City and therefore zoned uses and lot line setbacks were not a requirement at the time of development. Construction of a second unit in the space created by the 50-foot setback is consistent with other properties in the 200 block of Chiquita 5 Jonathan Lukoff, “City of Laguna Beach Application for Placement on Historic Register: 238 Chiquita Street,” September 27, 2008.
6 GPA, “Compliance with Secretary of the Interior’s Standards for Proposed Alterations to 238 Chiquita Street, Laguna Beach,” February 15, 2013,
https://mail.google.com/mail/u/0?ui=2&ik=4a84051eef&attid=0.1&permmsgid=msgf:1863655619752160328&th=19dd08e97efcec48&view=att&disp=inline&realattid=f_mohmifbe0& zw&acrobatPromotionSource=gmail_chrome-card.
7 Patrick W. Andrus and Rebecca H. Shrimpton, eds., How to Apply the National Register Criteria for Evaluation, National Register Bulletin 15 (National Park Service, Department of the Interior, 1995).
Alta Archaeological Consulting, LLC — 2681 Cleveland Avenue, Santa Rosa, CA 95403 www.altaac.com / office (707) 544-4206 / fax (707) 546-2135 Street that have two buildings on a single parcel. Although partially obscured from view currently and as proposed, the historic house will remain visible from the public right-of-way through implementation of the cantilevered design which maintains the site lines from the public right-of-way and preserves ocean views.
The Standards indicate alteration of the spaces that characterize the property, in this case, open space created by a 50-foot setback, should be avoided. Standard 2 does not indicate a change in space should be denied. In this case, constructing the second unit in the front of the historic house is consistent with the setting created by neighboring properties. The neighboring properties on the 200 block of Chiquita Street generally contain two units resulting in a uniform setback of approximately 13 and 20 feet. The proposed ADU would yield a 20-foot setback on the subject property, consistent with the setting created by the neighboring properties. Therefore, the proposed project complies with Standard
2. Standard 4: Most properties change over time; those changes that have acquired historic significance in their own right shall be retained and preserved.
The discussion of whether the 1961 stoop, porch, and pergola have achieved significance or not is moot. The HRG assertion these features have achieved significance was not supported by facts or other justification and was rejected by the Heritage Commission and Design Review Board during deliberations and was not carried forward to the DRB resolution. The proposed project would not alter the existing historic house because no work is proposed to the historic house. Therefore, no historic materials or alteration of features will occur. Although partially obscured from view currently and as proposed, the historic house will remain visible from the public right-of-way. Therefore, the proposed project complies with Standard 4.
Standard 9: New additions, exterior alterations, or related new construction shall not destroy historic materials that characterize the property. The new work shall be differentiated from the old and shall be compatible with the massing, size, scale, and architectural features to protect the historic integrity of the property and its environment.
The proposed project would not alter the existing historic house because no work is proposed to the historic house. Therefore, no historic materials or alteration of features will occur. As proposed, the project would not destroy historic materials that characterize the historic house because the ADU is detached and the landscaping was not previously identified as a significant character-defining feature of the historic house. The proposed ADU will be discernable as new construction based upon modern materials and design, and subordinate in massing, size, and scale as noted in the current proposed plans. Therefore, the proposed project will be differentiated from the old and compatible with the historic house.
In order to determine if the proposed project meets Standard 9, the setting impacts must behisthisto evaluated for the property itself but also in the context of the neighboring properties. The existing historic house will not be relocated and will retain its 50-foot setback. The proposed project includes landscaping and other open space elements such as walkways, which although reduced, will contribute to the retention of the setting within the parcel the historic house is located. Although the proposed project would impact the open space created by the 50-foot setback, this change is consistent with the setting created by the neighboring properties that contain two detached units. The neighboring properties reflect a variety of architectural styles constructed over a period of time and do not create
Alta Archaeological Consulting, LLC — 2681 Cleveland Avenue, Santa Rosa, CA 95403 www.altaac.com / office (707) 544-4206 / fax (707) 546-2135 a cohesive setting. The buildings on the neighboring properties do however generally create a uniform setback of approximately 13 to 20 feet, which the proposed project will contribute to the overall setting of the neighboring properties.
Conclusion
Based upon this additional analysis, the proposed project meets applicable state and City requirements for ADUs, including zoning and building codes, and the Standards. The proposed project would not result in a substantial adverse change to a historical resource as defined in the California Environmental Quality Act.
Preparer Qualifications
Carrie Chasteen possesses a MS in Historic Preservation, BAs in History and Political Science, and 25+ years preparing regulatory compliance documents, including Standards review. She meets and exceeds the Secretary of the Interior’s professional qualification standards as a Historian and an Architectural Historian (36 CFR Part 61).
Sincerely,
Carrie Chasteen
Senior Architectural Historian
[email protected]
Office: (707) 544-4206
1 McKay, Ann Marie CC
Subject: Appeal of DRB Decision re: 238 Chiquita Street Case No. Coastal Development Permit 26-1048
Attachments: City Council Letter re 238 Chiquita Street 3-13-26.pdf From: sweetlews
Sent: Sunday, April 5, 2026 7:18 AM
To: Orgill, Mark <[email protected]>; Jones, Hallie <[email protected]>; Whalen, Bob <[email protected]>; Rounaghi, Alex <[email protected]>; Kempf, Sue <[email protected]>
Cc: Montalto, Sammi CD <[email protected]>; McKay, Ann Marie CC <[email protected]> Subject: Appeal of DRB Decision re: 238 Chiquita Street Case No. Coastal Development Permit 26-1048 Honorable Mayor and Members of the City Council:
Attached you will find our letter regarding the subject project/property. While this may not be an item of which you are aware currently, it is our understanding that this appeal will be presented to and heard at the City Council meeting on May 13, 2026 beginning at 3:00 pm. We are out of the country during this time and, unfortunately, cannot be present to provide testimony. Our son, Brandon, plans to be present to speak on behalf of our family. We want to provide this letter in advance to make sure it is included in the record for your consideration. We have copied both Sammi Montalto, Associate Planner, who has been the lead for the City on this project as well as Ann Marie McKay, City Clerk.
If you have any questions for us and/or would like to talk with us and visit the property, we welcome those opportunities. We leave for our trip April 12, so the time for those communications is short. We will have access to email while we are away; although, it will be spotty.
We appreciate your receipt and consideration of our comment letter and the deliberation you will conduct on this matter.
Respectfully,
Mark and Melanie Lewis and the Lewis Family
248 Chiquita Street
(949) 677-0391 (Mark’s cell)