Laguna Beach City Council
May 13, 2026

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
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
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
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.
575
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.
576
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.
577
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.
578
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
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
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
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
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
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
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
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
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
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
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
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).
590
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
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.
592
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.
593
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
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
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
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.
597
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.
598
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
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).
600
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
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).
602
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
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
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)
605
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).
606
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
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).
608
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
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
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).
611
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).
612
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
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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