Historic Resources Group 31526 Valido Road, Laguna Beach | Supplemental Memo 1 MEMO
TO: CITY OF LAGUNA BEACH
ATTN: HEATHER STEVEN, SENIOR PLANNER
FROM: LAURA JANSSEN, SR. ARCHITECTURAL HISTORIAN;
MARIANA RUIZ, ARCHITECTURAL HISTORIAN
DATE: JUNE 3, 2025
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 The City asked HRG to review the report and comment on the report’s conclusions.
It is important to note that Chronicle Heritage reviewed the initial draft of the report HRG submitted in November 2024 and not the revised report submitted in February 2025. HRG updated the historic assessment report with additional research and updated the historic context statement for the development of South Laguna. Although HRG’s findings were unchanged in the updated report, the research was expanded and fact checked by local historian and landscape architect, Ann Christoph.
Generally, Chronicle Heritage 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 at the local level and the California Register. In fact, they failed to provide any additional research that would negate HRG’s findings or clarify any 1 “Historic Resource Assessment of 31526 Valido Road,
Laguna Beach 92651,” prepared by Chronicle Heritage, April 2025.
556 S. Fair Oaks Ave., Suite 101-514
Pasadena, CA 91105
Attachment 12
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Historic Resources Group 31526 Valido Road, Laguna Beach | Supplemental Memo 2 misconceptions about the Egan family and/or the development of South Laguna. They contend that because the setting has changed from rural farmland in the early 1900s to a residential development the subject property is not significant for its association with the Homestead Act of 1962, and therefore not eligible under Criterion A/1. HRG respectfully disagrees with this contention.
“Setting” is one of the seven aspects of integrity and a property must have historic significance and retain integrity to be eligible for designation as a historic resource. Historic integrity is the ability of a property to convey its significance. HRG noted in the Evaluation of Integrity that the subject property retains all aspects of integrity except setting. It is not necessary for a property to retain all of its historic physical features or characteristics. However, the property must retain sufficient features that enable it to convey its historic identity. The subject property retains integrity of location, design, materials, workmanship, feeling, and association and HRG concluded the subject property retains enough integrity to convey its significance. Even though the Chronicle Heritage report went to great lengths to note that since the setting had changed it was no longer able to convey its significance, it neglected to clarify this important point. HRG is not disputing that the subject property has lost integrity of setting, but the residence still retains its essential form and appearance from its period of significance (historic identity) and therefore its association with homesteading in South Laguna.
CLARIFICATION
Chronicle Heritage notes in its Abstract (pg. i), and in its Introduction (pg. 2), and again in its Findings and Conclusions (pg. 25) that the owner of the subject property does not consent to list the property in the City’s historic register. That is not at issue here. HRG did not assess the property against the City’s criteria because according to the revised Historic Preservation Ordinance, adopted in 2022 (not 2024), a Historic Resource for the purposes of CEQA is defined as a property that meets criteria for listing in the California Register. The City’s criteria for listing in the local Historic Register is reserved for those properties whose owners wish their properties to be listed in the local register. It is not necessary to assess a property against the local criteria when the property owners do not wish the property to be listed locally. However, in order to establish if a property is a historic resource, it must be evaluated against California Register criteria, which is how it was evaluated in the HRG report.
HRG’S RESPONSE
Chronicle Heritage agrees with HRG that the property does not meet criterion B/2 or C/3; however, they do not agree the property meets criterion A/1. HRG will rebut this conclusion.
HRG’s response follows and corresponds to the bold numbers below. The paragraph below is clipped from pg. 21 of the Chronicle Heritage report under NR and CR Criterion Evaluation:
Due to the progression of development over the course of time, the area surrounding the property that was once part of the Egan homestead no longer conveys an association with the Homestead Act. The subject property may be the last remaining vestige of the Homestead Act in south Laguna Beach; however, due to surrounding area being completely developed, it does not adequately reflect the Homestead Act period or period of time in which the Egan family farmed in the area.(1) The Egan’s property no longer possesses a pastoral agricultural feeling due to infill development, and therefore, does not possess sufficient integrity to convey an 445
Historic Resources Group 31526 Valido Road, Laguna Beach | Supplemental Memo 3 association with this early event in the history of south Laguna Beach.(2) Furthermore, south Laguna Beach was annexed by the City in 1987, and the subject property has no association with the early development of the City.(3) The subject property, therefore, is not eligible for listing on the NRHP or CRHR pursuant to Criterion A/1.
The urbanization of South Laguna follows twentieth century planning and land use policies seen throughout Southern California (and the United States) and the change in setting alone is not reason enough to disqualify the property from association with homesteading.
1. South Laguna, along with a majority of Southern California, took part in twentieth century urbanization, transitioning from agricultural land into a modern city. Residential and commercial development in South Laguna began in earnest in 1924 following suburban development models and the City Beautiful Movement seen throughout the United States. The Standard State Zoning Enabling Act (1922) and the Standard City Planning Enabling Act (1928), both prepared by the U.S. Department of Commerce, formed the basis for zoning laws across the country. These Acts enabled local communities to plan, and zone uses within their jurisdiction. Zoning laws allowed for regulation of construction use and type, as well as created property value — land assigned for commercial uses, for example, was seen as more valuable than land assigned for agriculture.2
Other federal policies further encouraged housing development in the 1930s. In 1934, the federal government passed the National Housing Act and created the Federal Housing Administration (FHA) to support housing development. The FHA insured longterm mortgages by private lenders, making it easier for citizens to borrow money for homes. FHA regulations also provided very low-risk financing to builders of large suburban subdivisions.3
Suburban development further boomed following World War II, with the return of servicemen supported by the GI Bill. A strong economy, the growing number of young families, and the desire — and economic ability — to own a home pulled the middle class away from the city. Developers met the demand for new housing with mass-produced large, single-family subdivisions on inexpensive farmland outside the city. Additionally, new highway infrastructure put these developments within an easy automobile commute of the city.
4 It is important to note that the Egan homestead, exclusively, was underdeveloped until the mid-1970s, when Tract No. 1243 and the neighborhood in Por. SW1/4, NW1/4, Sec. 5, T8S, R8W were finally developed. These two tracts span approximately 16 acres along the southern portion of the 40-acre homestead. The remaining acreage (approximately 24 acres) above the Egan property was acquired by Hermes Financial Corp in 1984 and dedicated to Orange County as part of the Aliso and Wood Canyons Wilderness Park as 2 “City and Suburb: An Overview of Urbanization in the
United States,” Summit County Utah,
https://www.summitcountyutah.gov/DocumentCenter/View/
20863/History-of-Urban-DevelopmentUS#:~:text=As%20a%20reaction%20to%20these,characteristi cs%20of%20these%20early%20suburbs, accessed May 2025.
3 “City and Suburb: An Overview of Urbanization in the
United States.” 4 “City and Suburb: An Overview of Urbanization in the United States.”
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Historic Resources Group 31526 Valido Road, Laguna Beach | Supplemental Memo 4 a wildlife conservation area.5 This large undeveloped area is preserved and reflects the original setting of the homestead during the period of significance. Refer to the Appendix B of HRG’s “Historic Resource Assessment: 31526 Valido Road” report for aerials of the homestead.
2. Although South Laguna no longer serves an agricultural purpose, the Egan property retains its integrity of location, design, materials, workmanship, feeling, and association to the Egan homestead. The modifications to the home from a one room cabin to a twobedroom house pertain to the period of significance (ca. 1909-1928), during which time the Egans maintained an active farming concern and expanded their household with the birth of their two children (Francis and Esther Egan). Like most homestead dwellings, small cabins were actively expanded and modified to accommodate the homesteaders’ growing needs over the years. In the case of the Egan residence, the house was fully developed by 1928, almost 20 years after it was first erected to “prove up” the land. A small addition was constructed on the northeast facade ca. 1945, and the windows were updated over time. These improvements, however, do not detract from the property’s ability to convey its significance to the Egan homestead as it developed during its period of significance. Refer to Appendix D of HRG’s “Historic Resource Assessment: 31526 Valido Road” report for historic photographs of the property.
3. HRG assessed historic significance within the context of the Homestead Act and how it played a role in the development of South Laguna during the period of significance from ca. 1909-1928. However, to our knowledge, the Egan property may be the last remaining property associated with homesteading in all of Laguna Beach.
The paragraphs below are clipped from pp. 24-25 of the Chronicle Heritage report under Findings and Conclusions:
Chronicle Heritage does not concur with HRG’s finding that the subject property adequately reflects or conveys an association with the Homestead Act of 1862. The Homestead Act encouraged westward expansion and economic growth. At its core, the Homestead Act was the catalyst that pushed Euro-Americans from the east and middle of America to migrate to the west for an opportunity at land ownership. The stipulations for establishing a homestead required a homesteader “prove up” their land within five years of ownership, including constructing living quarters and agricultural fields and/or owning herds of grazing animals. (4) Because the Egan Homestead was established in the County prior to the incorporation of the City and the annexation of South Laguna, it is appropriate to consider the homestead within the context of the County. Numerous homesteads were established within the County, and the enactment of the Egan Homestead is not a rare or unique event. (5) Newspaper articles recorded that Egan farmed melons and string beans and shipped them by rail to markets in Los Angeles and San Francisco. There was no information to assert that any profits gained from farming his homestead were allocated to the City or to the immediate area of South Laguna for further development that would promote economic growth in area. (6) Additional information regarding Egan indicated that the subject property was not his 5 This area excludes the almost 14,300 square feet of land deeded to the South Coast Water District to build a water reservoir on the northwest extreme of the homestead.
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Historic Resources Group 31526 Valido Road, Laguna Beach | Supplemental Memo 5 permanent place of residence. Egan often travelled from Spadra (present day Pomona) to the area of what is now the City/South Laguna on multi-day camping trips and sought to stake a claim to undeveloped land. An article in the Pomona Progress Bulletin indicated that in 1920, Egan and his family relocated back to Spadra to a home they recently built. (7) Furthermore, there was no additional information found in newspaper articles beyond 1920 to assert that the Egan homestead was actively producing crops for sale within California or locally in the area. (8)
The subject property may be the oldest intact portion of the property within the area of William Egan’s 40-acre homestead; however, the progression of development over the course of time has altered the setting, and it does not wholistically exude the feeling or embody what once was an active farming homestead. Based on digital photographs, the Egan homestead land and surrounding parcels were completely developed by the early 1970s. Therefore, any association with homesteading was lost over 40 years ago. (9)
4. The significance of the Homestead Act of 1862 is not in question. However, by the late 1930s, approximately 10 percent of California land had been claimed by homesteaders; contributing significantly to the agricultural economy of the state and accounting for about 65 percent of new farms.6 These homesteaders laid the foundation for some of the first roads, ditches, and wells; they planted some of the first crops in the region; and contributed to the food supply of nearby towns and rural communities. Their toil, patience, agricultural experimentation, and innovation, faced with the hardship of natural elements and disasters, and their resolve to defend hard-earned land for themselves and their families, exemplifies the legacy of the Homestead Act and its role in the settlement and agricultural expansion of California.7
5. There were only 70 homestead claims filed in Orange County under the Homestead Act due to the limited amount of available land and water. Most of California was developed under the Spanish, and later Mexican, the land grant system which created the Ranchos.
The Irvine Ranch (1864) held approximately one-third of Orange County land for farming and ranching, which they did not begin to subdivide until the 1960s. The relative success of Orange County’s homesteaders, who all lived south of the Santa Ana River, depended a great deal on the early efforts of the Santa Ana Valley Irrigation Company, for irrigation.8 The small number of homesteaders farming the area also gave them each a better opportunity to succeed at the produce markets in the new towns of Tustin, Orange, and Santa Ana; and in the case of the Egans and Shrewsburys, as far north as Los Angeles and San Francisco. The first successful homesteader in Laguna, George Thurston, Sr., also sold his produce in Los Angeles, which was a five-day trip by wagon.
In order to make their farms a success they had to go where the markets were. These pioneers fulfilled both the spirit and the letter of the Homestead Act in Orange County, where limited land and water availability proved difficult to succeed as farmers. The establishment of the Egan homestead was not a rare or unique event, there were other homesteaders in South Laguna; however, the Egan residence is still extant and is the 6 Josh Sides, Backcountry Ghosts: California Homesteaders and the Making of a Dubious Dream (University of Nebraska Press: 2021), e-book, 23.
7 Sides, Backcountry Ghosts, 23-24. 8 Sides, Backcountry Ghosts, 211. 448
Historic Resources Group 31526 Valido Road, Laguna Beach | Supplemental Memo 6 last residence associated with homesteading in South Laguna, which makes that association rare and unique.
6. The Egan homestead was established primarily for the benefit of the Egan and Shrewsbury families. However, during times of harvest seasonal employment was offered to transient workers. The agricultural stimulation of an otherwise arid and rough terrain, and food supply to local markets, lead to the development of rural communities, small towns, and ultimately cities, as was the case in South Laguna.
7. The Egans predominantly lived in Spadra from 1910 to 1914, they split their time between Spadra and South Laguna from 1914 to 1928 when the family relocated permanently to Laguna Beach.9 Egan also had a farm in Spadra so he devoted time to oversee both operations. However, HRG’s report found the residence was not significant for its association with William F. Egan (Criterion B/2), so the amount of time he spent on either farm is not relevant.
8. The 1930 US Census indicates William Egan’s occupation as a farmer, and the 1930 South Orange County city directory lists him as an apiarist.10 Those are the two occupations that he engaged in since 1880 when he went to live with his uncle James Shrewsbury after his mother’s death. With this information, it is safe to assume he was still farming and keeping bees on his homestead until his death in 1930. Residential development began in Coast Royal in 1924, which was located to the west and south of the Egan homestead, and by 1928 Tract No. 849 was being developed directly south of the Egan homestead in Three Arches. However, the Egan homestead was still intact and had not yet been subdivided indicating it was still a viable business from 1920 util 1930.
9. As noted above, the setting of the Egan homestead has been altered by the progression of development. The Egan homestead was one of the last remaining areas to be subdivided in South Laguna, and most of the northern portion of the original 40-acre homestead is still undeveloped and has been retained as a wildlife conservation area, additionally the residence currently backs up to this area. Even though the setting has been altered it is not inconceivable that the property as it exists today could be recognized by the Egan family. Refer to contemporary aerial photograph on pg. 11 of HRG’s “Historic Resources Assessment: 31526 Valido Road, Laguna Beach.” 9 “Mrs. Bertie Egan, Pioneer Resident, Expires Sunday,” South Coast News, January 18, 1949.
10 1930 US Census for William F. Egan, Ancestry.com,
accessed October 2024; South Orange County City Directory, Ancestry.com, accessed October 2024.
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