Laguna Hills City Council
September 23, 2025

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4 Summary of Significance Evaluation Findings ................................................................................................ 33

EXHIBIT
1 1972 aerial photograph (left) showing the API partially developed; 1980 aerial photograph (right) showing the extant API (outlined in red)......................................................................................................................... 19

PHOTOGRAPHS
Photograph 1. Primary (north) elevation of Map ID 1a, view looking southwest. Photograph taken on July 26, 2024. ................................................................................................................................................... 22 Photograph 2. Primary (north) and west elevations of Map ID 1a, view looking southeast. Photograph taken on July 26, 2024. ................................................................................................................................................... 23 Photograph 3. Primary (south) and west elevations of Map ID 1b, view looking northeast. Photograph taken on July 26, 2024. ................................................................................................................................................... 24 Photograph 4. Primary (south) and east elevations of Map ID 1b, view looking northwest. Photograph taken on July 26, 2024. ................................................................................................................................................... 24 Photograph 5. Primary (south) and west elevations of 25250 La Paz Road, view looking northeast. Photograph taken on July 26, 2024. ................................................................................................................................... 25 Photograph 6. East and rear (north) elevations of 25250 La Paz Road, view looking southeast. Photograph taken on July 26, 2024............................................................................................................................................... 26 Photograph 7. Primary (north) and east elevations of 25252 La Paz Road, view looking southwest. Photograph taken on July 26, 2024. ................................................................................................................................... 27 Photograph 8. East and rear (south) elevations of 25252 La Paz Road, view looking northwest. Photograph taken on July 26, 2024............................................................................................................................................... 27 Photograph 9. Primary (north) and west elevations of Map ID 4, view looking southeast. Photograph taken on July 26, 2024. .......................................................................................................................................................... 28 Photograph 10. Primary (north) and east elevations of Map ID 4, view looking southwest. Photograph taken on July 26, 2024. ................................................................................................................................................... 29

FIGURES
Figure 1 Project Location......................................................................................................................................3 Figure 2 Built Environment Area of Potential Impacts..................................................................................... 11

APPENDICES
A Interested Party Correspondence
B DPR Form

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Acronyms and Abbreviations
Acronym/Abbreviation Definition
ACHP Advisory Council on Historic Preservation
API Area of Potential Impacts
APN Assessor’s Parcel Number
BERD Built Environment Resource Directory
CCR California Code of Regulations
CEQA California Environmental Quality Act
CFR Code of Federal Regulations
CHRIS California Historical Resources Information System City Laguna Hills
County Orange County
CRHR California Register of Historical Resources
DPR Department of Parks and Recreation
NEPA National Environmental Policy Act
NHPA National Historic Preservation Act
NRHP National Register of Historic Places
OHP Office of Historic Preservation
PRC Public Resources Code
Project La Paz Village Senior Housing Project
SCCIC South Central Coastal Information Center

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1 Introduction
This Built Environment Inventory and Evaluation Report documents the identification and evaluation of built environment cultural resources within or adjacent to the proposed La Paz Village Senior Housing Project (project) that may require additional analysis for compliance under the California Environmental Quality Act (CEQA). This report includes the following components: (1) an introduction including project location, description, the Area of Potential Impacts (API), and regulatory context; (2) background research, which includes a focused records search review of previously recorded built environment resources included in the California Historical Resources Information System (CHRIS), a review of historical maps and aerial photographs, and the field methodology and the intensive-level survey of the API; (3) the development of applicable historic contexts for the project area; (4) an evaluation of significance for all resources within the API; and (5) findings and conclusions.

1.1 Project Location
The project site is approximately 4 acres and consists of one contiguous parcel located at 25254 La Paz Road (APN 620-211-17) in Laguna Hills, Orange County, California (Figure 1, Project Location). The project site is in an urban setting on the south side of La Paz Road between MacKenzie Street to the west and McIntyre Street to the east. It is located approximately 0.20 miles west of Highway 5. The project site is currently fully developed with four commercial buildings surrounded by parking lots. The surrounding area primarily contains single-family residences with commercial buildings along La Paz Road, east of the project site.

1.2 Project Description
The project includes the construction of a senior living podium-style development in the City of Laguna Hills (City), California. The proposed development would be up to 5 stories and would include 180 age-restricted units, of which 144 would be market rate and 36 would be affordable units, along with 255 parking spaces in a parking garage on the basement and at-grade parking on the first level. The project would have a maximum height of 60.3 feet, with a two- to four-story wing at the west and east ends of the building and a five-story portion in the north and center of the building. The lobby would be on the east side of the building. The project would include 21,110 square feet of open space, including two courtyards at the center of each building wing, aboveground courtyards, and a rooftop deck on level five on the McIntyre Street side. Resident amenities would include the following: a lounge, salon, pantry, pool, two dining rooms, club room, golf room, whiskey room, and theater.

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Project Site
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La Paz Village Senior Housing
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FIGURE 1

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1.3 Regulatory Setting
While the project as currently planned is subject only to state and local regulatory conditions, federal regulations are also provided here for reference should they be relevant in the future. The following sections provide a brief overview of the federal and state regulatory framework through which historic properties and historical resources are identified and evaluated.

1.3.1 Federal
National Historic Preservation Act (54 USC § 300101 et seq., including Section 106 of the NHPA, 54 USC § 306108)
The National Historic Preservation Act (NHPA) established the National Register of Historic Places (NRHP) and the Advisory Council on Historic Preservation. Under the NHPA, significant cultural resources are referred to as historic properties, which include any prehistoric or historic district, site, building, structure, or object included in, or determined eligible for inclusion in, the NRHP. Historic properties that are designated by the Secretary of the Interior to be National Historic Landmarks are nationally significant historic places that possess exceptional value or quality in illustrating or interpreting the heritage of the United States. A property is considered historically significant if it meets one of the NRHP criteria and retains sufficient historic integrity to convey its significance.

Implementing Regulations for Section 106 of the NHPA (36 CFR Part 800) Section 106 of the NHPA requires federal agencies to consider the effects of their undertakings on historic properties. The Section 106 process consists of four principal steps: 1) initiation of the Section 106 process, which includes identifying and initiating consultation with Native American tribes, local governments, and other interested parties; 2) identification of historic properties; 3) assessment of adverse effects; and 4) delineation of stipulations to resolve adverse effects in an agreement document.

Section 106 affords the Advisory Council on Historic Preservation and the State Historic Preservation Officer, as well as other consulting parties, a reasonable opportunity to comment on any project that would adversely affect historic properties. The Advisory Council on Historic Preservation is an independent administering agency that develops procedures at the federal level to protect cultural resources included in, or eligible for inclusion in, the NRHP. The State Historic Preservation Officers administer the national historic preservation program at the state level, in addition to reviewing NRHP nominations, maintaining data on historic properties, and consulting with federal agencies during the Section 106 review.

The NRHP criteria for evaluation (36 Code of Federal Regulations [CFR] Section 60.4) considers the quality of significance in American history, architecture, archaeology, engineering, and culture is present in districts, sites, buildings, structures, and objects that possess integrity of location, design, setting, materials, workmanship, feeling, and association, and that:

Are associated with events that have made a significant contribution to the broad patterns of our history Are associated with the lives of persons significant in our past

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Embody 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
Have yielded or may be likely to yield, information important in prehistory or history To be listed in the NRHP, a property must not only be shown to be significant under the NRHP criteria, but it also must have integrity. Integrity is the ability of a property to convey its significance. Because the concept of integrity is based on significance, the assessment of a property’s integrity can only proceed after its significance has been fully established. In addition to meeting at least one of the significance criteria discussed above, the assessment of integrity requires consideration under the following seven aspects or qualities: location, design, materials, workmanship, setting, feeling, and association. To retain integrity, a property will always possess several, and generally most, of these aspects (NPS 1995:44).

Certain properties are not typically considered for listing in the NRHP: religious properties, moved properties, birthplaces and graves, cemeteries, reconstructed properties, commemorative properties, and properties achieving significance within the past 50 years. These properties may be eligible for listing in the NRHP if the property meets one of the four criteria listed above and if the property also meets the appropriate Criteria Consideration for the property.

National Environmental Policy Act (42 USC § 4331 et seq.) and CEQ NEPA Regulations (40 CFR § 1500 et seq.)
The National Environmental Policy Act (NEPA), as amended, establishes the federal government’s policy for protecting important historic cultural, and natural aspects of our national heritage during the planning for federal projects. All federal or federally assisted projects requiring action pursuant to Section 102 of the NEPA must take into account the effects of those projects on cultural resources. In considering whether an action may “significantly affect the quality of the human environment,” the NEPA regulations require that an agency must consider, among other things, unique characteristics of the geographic area such as proximity to historic or cultural resources (40 CFR § 1508.27(b)(3) and the degree to which the action may affect districts, sites, highways, structures, or objects listed in or eligible for listing in the NRHP. The NEPA regulations also require that, to the fullest extent possible, agencies prepare Environmental Impact Statements concurrently and integrated with impact analyses and related surveys and studies required by the NHPA. When Section 106 of the NHPA and NEPA are integrated, project impacts that cause adverse effects under Section 106 are described in the Environmental Impact Statement.

1.3.2 State
California Environmental Quality Act (PRC § 21083.2) and CEQA Guidelines (14 CCR § 15064.5) CEQA requires that the lead agency consider the impacts of a project on historical resources. Public Resources Code (PRC) Section 21084.1 defines historical resources as those listed, or eligible for listing, in the California Register of Historical Resources (CRHR), or those officially designated or recognized as historically significant by a local government pursuant to a local county or city ordinance or jurisdiction, unless the preponderance of the evidence demonstrates that the resource is not historically or culturally significant. Historical resources also include “historic properties” in California that are listed, or determined eligible for listing, in the NRHP and CRHR. The CEQA

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Guidelines provide specific guidance for determining the significance of impacts on historical resources. As described in in Section 15064.5(b) of the CEQA Guidelines, a “project with an effect that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment.”
 A “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 (Section 15064.5[b][1]).  The significance of an historical resource is materially impaired when a project:
- 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 (Section 15064.5[b][2][A]); or - Demolishes or materially alters in an adverse manner those physical characteristics that account for it inclusion in a local register of historical resources pursuant to section 5020.1[k] of the Public Resources Code or its identification in an historical resources survey meeting the requirements of section 5024.1[g] of the Public Resources Code, unless the public agency reviewing the effects of the project establishes by a preponderance of the evidence that the resource is not historically or culturally significant (Section 15064.5[b][2][B]); or
- Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historic significance and that justify its inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA (Section 15064.5[b][2][B]); or
The CEQA Guidelines also provide guidance on minimizing or avoiding significant adverse impacts on historical resources as outlined in the following provisions of Section 15064.5(b)(3)-(5).  Generally, 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, shall be considered as mitigated to a level of less than a significant impact on the historical resource (Section 15064.5[b][3]).  A lead agency shall identify potentially feasible measures to mitigate significant adverse changes in the significance of an historical resource. The lead agency shall ensure that any adopted measures to mitigate or avoid significant adverse changes are fully enforceable through permit conditions, agreements, or other measures (Section 15064.5[b][4]).
 When a project will affect state-owned historical resources, as described in Public Resources Code Section 5024, and the lead agency is a state agency, the lead agency shall consult with the State Historic Preservation Officer as provided in Public Resources Code Section 5024.5. Consultation should be coordinated in a timely fashion with the preparation of the environmental documents (Section 15064.5[b][5]).

California Register of Historical Resources (PRC § 5024.1 and 14 CCR § 4850) PRC Section 5024.1 establishes the CRHR, which lists all significant resources in California that are considered to be historical resources. In California, the term “historical resource” includes, but is not limited to, “any object,

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building, structure, site, area, place, record, or manuscript which is historically or archaeologically significant, or is significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California” (California PRC Section 5020.1[j]). In 1992, the California legislature established the CRHR “to be used by state and local agencies, private groups, and citizens to identify the state’s historical resources and to indicate what properties are to be protected, to the extent prudent and feasible, from substantial adverse change” (California PRC Section 5024.1[a]). The criteria for listing resources in the CRHR were expressly developed to be in accordance with previously established criteria developed for listing in the NRHP. As such, a resource is considered historically significant if it meets at least one of the following criteria outlined under PRC Section 5024.1(c):

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.

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

In addition to meeting one of the significance criteria described in PRC Section 5024.1(c), a resource must also possess sufficient integrity to qualify for listing in the CRHR. Integrity as defined in 14 California Code of Regulations (CCR) Section 4852(c) as “the authenticity of an historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource’s period of significance” as evaluated with regard to the resource’s retention of location, design, setting, materials, workmanship, feeling, and association. Historical resources that lack sufficient integrity to meet the criteria for listing in the NRHP may still be eligible for listing in the CRHR if they have the potential to yield significant scientific, historical information, specific data. The special considerations within the CRHR for certain property types are limited to moved buildings, structures or objects; historical resources achieving significance within the past 50 years; and reconstructed buildings. The CRHR includes not only listed prehistoric and historic cultural resources but also resources that are identified through local historical resource surveys or designated under local ordinances provided the survey and ordinance meet the criteria in 14 CCR Section 4852(e) and (f).

1.4 Area of Potential Impacts
The API is the study area delineated to assess potential impacts from the construction and operation of the project on both archaeological and historic built environment resources. The API for built environment resources encompasses the geographic area or areas within which the project may directly or indirectly cause a substantial adverse change in the significance of a known or unknown historical resource. A substantial adverse change in the significance of a historical resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of the resource is materially impaired (14 CCR Section 15064.5[b][1]). Under CEQA, material impairment of a historical resource is considered a significant impact (or effect), which can be direct, indirect, or cumulative.1 A direct or primary effect on a historical resource is one that is caused by the project and occurs at the same time and place (14 CCR Section 15358[a][1]). Examples of direct effects that are caused by, and immediately related 1 As used in the CEQA Guidelines and 14 CCR Section 15358, the terms “effects” and “impacts” are synonymous in this report.

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to, the project include, but are not limited to, demolition, destruction, relocation, and alteration of a historical resource as a result of ground disturbance and other construction activities. Direct effects, however, are not limited to physical effects and, in certain circumstances, can be visual, vibratory, auditory, or atmospheric in nature if the effect is immediate and results in the material impairment of the significance of a historical resource. Visual intrusions within the viewshed of a historical resource, for example, could result in the material impairment of the resource’s integrity of setting if an unencumbered view of the surrounding area or a specific area is a characteristic that contributes to the significance of the resource. Similarly, operational noise that exceeds the ambient level of a sensitive noise receptor can cause material impairment to a historical resource that derives part or all its significance from an inherently quiet auditory setting.2 Finally, atmospheric intrusions, such as those caused by the introduction of high levels of fugitive dust emissions or chemical pollutants, can result in adverse effects that directly and physically affect biological landscape features that have been identified as historical resources for the purposes of CEQA. Overall, while direct effects clearly include physical effects, they may also include other types of effects that are visual, vibratory, auditory, or atmospheric in nature if the effect is caused by and occurs at the same time and place as the project and there is no other intervening cause between the activities or components of the project and the historical resource.

By contrast, an indirect or secondary effect is a reasonably foreseeable effect caused by the project that occurs later in time or is farther removed in distance. Indirect effects may include growth-inducing effects and other effects related to induced changes in the pattern of land use, population density, or growth rate, and related effects on air and water and other natural systems, including ecosystems (14 CCR Section 15358[a][2]). Because these types of effects are not immediately related to the project, they are considered secondary effects.

Cumulative impacts refer to two or more individual effects that, when considered together, are considerable or compound or increase other environmental impacts. The individual effects may be changes resulting from a single project or a number of separate projects. The cumulative impact from several projects is the change in the environment that results from the incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects. Cumulative impacts can result from individually minor but collectively significant projects taking place over a period of time (14 CCR Section 15355[a]–[b]). The API for cumulative impacts, if any exist, would include the API for direct effects, indirect effects, or both, because in order for a cumulative impact to exist, a historical resource must first be directly or indirectly affected by the project.

1.4.1 Area of Potential Impacts for the Proposed Project Delineation of the API considered the proposed project activities in conjunction with historic era-built resources that are 45 years of age or older (those built in or prior to 1978) that may sustain impacts due to the construction or operation of the project.3 The delineation of the API is influenced by a project’s planned activities or setting, the 2 Construction noise that exceeds the ambient level of a sensitive noise receptor is not analyzed because it is considered a temporary impact that would not have an adverse effect on historical resources, as it would not cause physical damage and would not permanently alter or diminish the integrity of such resources. Temporary construction noise would not result in a substantial adverse change in the significance of a historical resource and, therefore, would not cause a significant impact under CEQA. 3 While the 50-year threshold is generally used for listing resources in the National Register of Historic Places (NRHP) and the California Register of Historical resources (CRHR), the California Office of Historic Preservation’s (OHP) Instructions for Recording Historical Resources recommends recording “any physical evidence of human activities over 45 years . . . for the purposes of inclusion in the OHP’s filing system.” It also allows for the “documentation of resources less than 45 years . . . if those resources have been formally evaluated, regardless of the outcome of the evaluation.” Further, the guidance notes that the 45-year threshold recognizes that there is commonly a 5-year lag between resource identification and the date that planning decisions are made, and thus it explicitly encourages the collection of data about resources that may become eligible for the NRHP or CRHR

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scale and nature of the project, and the types of impacts (direct or indirect) that may result from project implementation.

The vertical above ground extent of the API is anticipated to be five-stories, which is the height of the senior housing development proposed for construction on the project site. The horizontal limits of the API considered the proposed project components, which are limited to the footprint of the project site at 25254 La Paz Road (APN 620-211-17), as well as three historic-age buildings located at 25250 La Paz Road (APN 620-211-18), 25252 La Paz Road (APN 620-211-15), and 25758 La Paz Road (APN 6220-211-09) adjacent to the project site. These properties were included in the API in consideration of potential visual, vibratory, auditory, and atmospheric effects. All properties in the API are included in Table 1.

Additional considerations used to justify the delineation of the API include the following:
 The area of direct physical effect is confined to the project site wherein all ground disturbance associated with the project will occur. Other construction activities that would occur within the boundary of the project site include the demolition of existing buildings for the construction of a five-story 180-unit senior living development with an underground parking garage. Because of the geographically constrained nature of these activities, the area of direct physical impact is confined to the project site as presented in Figure 2, Built Environment Area of Potential Impacts.
 The area of direct effect encompasses the project site as well as three adjacent properties at 25250 La Paz Road (APN 620-211-18), 25252 La Paz Road (APN 620-211-15), and 25758 La Paz Road (APN 620- 211-09) where potential impacts from visual, vibratory, auditory, or atmospheric effects were also considered.
 Since there are no reasonably foreseeable project activities that would occur later in time or that would be farther removed in distance that could indirectly affect historical resources, the API contains no geographic areas under consideration for indirect effects.

Table 1. Resources Located within the Area of Potential Impacts Map ID Property Type APN Address
Year
built Location
Evaluation
Status
1a Commercial 620-211-17 25254 La Paz Road 1974 Project site Previously unevaluated
1b Commercial 620-211-17 25254 La Paz Road 1974 Project site Previously unevaluated
2 Commercial 620-211-18 25250 La Paz Road 1974 Adjacent to project site
Previously
unevaluated
3 Commercial 620-211-15 25252 La Paz Road 1974 Adjacent to project site
Previously
unevaluated
4 Commercial 620-211-09 25758 La Paz Road 1974 Adjacent to project site
Previously
unevaluated
within that planning period. More restrictive criteria must be met before the resources included in OHP’s filing system are listed, found eligible for listing, or otherwise determined to be important in connection with federal, state, and local legal statuses and registration programs (OHP 1995: 2).

La Paz Rd
Sycamore Ln
Rickenbacker Rd
Mackenzie St
McIntyre St
Map ID 1a
Map ID 2
Map ID 1b
Map ID 3
Map ID 4
Project Site
Area of Potential Impacts
Map IDs
Map ID 1a: 25254 La Paz Road (APN 620-211-17)
Map ID 1b: 25254 La Paz Road (APN 620-211-17)
Map ID 2: 25250 La Paz Road (APN 620-211-18)
Map ID 3: 25252 La Paz Road (APN 620-211-15)
Map ID 4: 25758 La Paz Road (APN 620-211-09)
0 40 80 n Feet Date: 2/5/2025 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Figure2_BuiltEnvironmentAreaofPotentialImpacts Layout: Figure2_BuiltEnvironmentAreaofPotentialImpacts SOURCE: Esri World Imagery 2023
La Paz Village Senior Housing Project
Built Environment Area of Potential Impacts
FIGURE 2

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2 Literature Review,
Background Research, and Methods
This section provides the results of the CHRIS records search at the South Central Coastal Information Center (SCCIC), a summary of archival research methods and additional records reviews, a summary of interested party correspondence outreach, and field survey methodology.

2.1 CHRIS Records Search
On July 18, 2024, Dudek conducted a search of the CHRIS at SCCIC, located on the campus of California State University, Fullerton. The search included any previously recorded cultural resources and investigations within a 1-mile radius of the proposed project site. The CHRIS search also included a review of the NRHP, the CRHR, the California Points of Historical Interest list, the California Historical Landmarks list, the Archaeological Determinations of Eligibility list, and the California State Historic Resources Inventory list. Dudek reviewed the SCCIC records to determine whether the implementation of the proposed project would have the potential to impact any known and unknown cultural resources. The results presented below only discuss previously conducted cultural resource studies that include historic built environment resources and previously recorded historic built environment resources. The CHRIS records did not identify any built environment resources within the project site or within 0.5 miles of the project site. One previously conducted cultural resource study was identified.

2.1.1 Previously Conducted Cultural Resource Study
Results of the cultural resources records search indicate that one previous cultural resource study has been conducted within 0.5 miles of the proposed project site in 2011. The previous study does not overlap with the project site and is not immediately adjacent to the proposed project site, indicating that the entirety (100%) of the proposed project site has not been subject to any previous built environment investigations. Table 2, below, includes the cultural resource study that appears to include built environment resources. This study primarily consists of cultural resource records searches. However, copies of the reports were not provided by SCCIC. For the full results of the records search including archaeological resource studies, see Dudek’s 2024 Cultural Resources Chapter for the La Paz Village Senior Housing Project, Laguna Hills, Orange County, California.

Table 2. Previous Built Environment Resources Study within the API IC Report ID Author Year Report Title
OR-04223 Flynn, Chris 2011 Notification of Finding of No Adverse Effect with Standard Conditions for the Bridge Deck Maintenance and Sealing at 30 Locations Throughout Orange County, California
Note: Area of Potential Impacts

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2.2 Additional Records Reviewed
The following sources provide additional information regarding the potential for built environment resources to be located within the API. This information was used to understand the history of the area and how the landscape has changed and developed over time.

Built Environment Resource Directory
The California Office of Historic Preservation (OHP) maintains the Built Environment Resource Directory (BERD), an inventory of built environment cultural resources that are processed through OHP’s office. On July 18, 2024, Dudek searched for the La Paz Village commercial complex and its associated addressed in BERD for Orange County. The properties in the API were not included in the BERD.

Calisphere
Calisphere provides access to 2,000 collections contributed by more than 300 cultural heritage organizations in California, including universities, libraries, archives, museums, and historical societies. Dudek searched for subject properties’ addresses and other keywords on Calisphere on July 18, 2024. This search did not identify any materials pertaining to the subject property.

Online Archive of California
The Online Archive of California provides free public access to detailed descriptions of primary resource collections maintained by more than 300 contributing institutions including libraries, special collections, archives, historical societies, and museums throughout California and collections maintained by the 10 University of California campuses. Dudek searched for historical tenants and addresses associated with the subject properties on Online Archive of California on July 18, 2024, and did not identify any relevant materials.

City of Laguna Hills City Clerk
Dudek submitted a public records request for building permits associated with the subject properties on July 18, 2024 (Reference No: 24-165). The City responded to the public records request on July 24, 2024, and sent Dudek digital building permits for the subject properties. Dudek reviewed all available permits.

Historic Aerials
Dudek conducted a review of historic aerial photographs as part of the archival research effort for the proposed project. The aerial photographs provided a general idea of growth in the neighborhoods and on the subject properties, Relevant information is incorporated into Section 3, Historic Context; Section 4 Property Histories; and Section 5, Results of Identification and Evaluation Efforts (NETR 2024a).

Historical Topographic Maps
Dudek conducted a review of historic topographic maps as part of the archival research effort for the proposed project. The topographic maps provided a general idea of growth in the area and on the subject property (NETR 2024b).

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Historical Newspapers
Dudek reviewed historical newspapers from the California Digital Newspaper Collection and Newspapers.com covering Laguna Hills and the surrounding area to understand the development of the City and the subject properties. These documents were used in the preparation of Section 3, Historic Context; Section 4 Property Histories; and Section 5, Results of Identification and Evaluation Efforts.

2.3 Interested Party Correspondence
On July 25, 2024, Dudek Architectural Historian Katie Ahmanson, MHC, sent an outreach letter and figure depicting the project area to the Laguna Hills Historical Society, the Laguna Woods History Center, the Orange County Historical Society, the Laguna Woods Village Library, and the Laguna Hills Technology Library. The letter provided a brief description of the proposed project and requested information about historic and cultural components in or near the project area. To date, no responses have been received. Copies of the interested party correspondence have been submitted in conjunction with this project are in Appendix A.

2.4 Field Survey
Ms. Ahmanson conducted an intensive survey of the project study area on July 26, 2024. Ms. Ahmanson meets the Secretary of the Interior’s Professional Qualifications Standards for architectural history. The survey entailed walking around the exteriors of each property, documenting the properties with notes and photographs, specifically noting character-defining features, spatial relationships, observed alterations, and examining any historic landscape features associated with the properties.

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3 Historic Context
This context is provided to ascertain what significant themes concern the history of the subject property. Dudek provides this information to better understand the context of any of the identified previously recorded or newly documented resources in the API. It begins with a general overview of the development of the Laguna Hills. The context then provides a discussion of the subject property’s development, including the history of owners and occupants, and the property typology (neighborhood shopping center).

3.1 Historical Overview of Laguna Hills
The City of Laguna Hills is located Orange County, California, and is named after its proximity to Laguna Canyon.

Laguna Hills was developed on the former Rancho Niguel land in 1894. After Mexico won its independence from Spain in 1822, Alta California became part of the Mexican Republic, and the Mexican government opened California to foreign trade. Private land grants were issued in the early 1820s, creating the rancho system of large agricultural estates. Rancho Niguel was granted to Juan Avila in 1842 and extended along the coast from Laguna Canyon to San Juan Creek, encompassing the present-day cities of Laguna Niguel, Aliso Viejo, and Laguna Hills. By 1848, America assumed formal control of California with the Treaty of Guadalupe-Hidalgo and introduced Anglo culture and society. Avila continued to own the ranch until 1865, when he sold the property to John Forster. In 1895, Lewis Moulton and his partner Jean Pierre Daguerre purchased the property, and it became known as Moulton Ranch.

Moulton and Daguerre used the property to raise cattle and sheep as well as to grow barley and beans (City of Laguna Hills 2024; City of Laguna Niguel 2024). Over time, Moulton increased the property from 19,000 acres to 26,000 acres. By 1908, Daguerre was granted one-third ownership of the ranch. Moulton and Daguerre continued to cultivate the land throughout the early 1900s as their ranch grew in success (City of Laguna Hills 2024).

The first half of the twentieth century saw little development as the area remained primarily agricultural. In 1938, Moulton passed away, so his wife, Nellie, went on to manage Moulton Ranch with Daguerre (City of Laguna Hills 2024). Historic aerial photographs of the area during this period indicate that the land surrounding the ranch was primarily undeveloped rural landscape (NETR 2024a). The area comprising modern-day Laguna Hills remained undeveloped agrarian land until after World War II (1939–1945), when a massive wave of migration and corresponding building boom occurred throughout California. Development began in present-day Laguna Hills in the early 1950s, when Moulton Ranch was subdivided and sold to individual buyers who constructed single-family residences (City of Laguna Hills 2024). Historic newspaper research indicates that the Mission Viejo Company purchased 11,000 acres of the nearby Mission Viejo Ranch in Mission Viejo to develop the first planned community in 1964; it also developed much of the surrounding areas of Mission Viejo and Aliso Viejo, as well as parts of Laguna Hills (CD 1964: 1; Moulton Museum 2024).

Increased residential construction also led to a rise in commercial properties and infrastructure to support the new population. By 1970, the Laguna Hills Plaza was constructed to serve the communities of Laguna Hills, El Toro, South Laguna, Laguna Niguel, Laguna Beach, Dana Point, Capistrano Beach, San Juan Capistrano, and San Clemente, followed by the Laguna Hills Mall in 1973 and the Wild West Plaza by 1974 (AB 1969: 31; CD 1972:
7; SPN 1976: 8). While development increased, agriculture decreased, and Moulton Ranch was completely sold off in 1976, when the Mission Viejo Company purchased the ranch’s last lot. By then, the land comprising the former Moulton Ranch had become part of the present-day communities of Aliso Viejo, Laguna Hills, Laguna Niguel, and Laguna Woods. Residential and commercial growth of Laguna Hills continued throughout the second half of the

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twentieth century, although the area remained partially developed until the late 1980s (City of Laguna Hills 2024; NETR 2024a).

Efforts to incorporate the community of Laguna Hills began in 1987 with an approximate population of 45,000 residents (City of Laguna Hills 2024). By 1989, Laguna Hills was the fourth community proposed for incorporation in Orange County in 18 months, with two cities—Mission Viejo and Dana Point—incorporated in the year prior. However, voters in 1989 opposed the incorporation, with most of the opposition stating a fear of higher taxes (LAT 1989: 51). By 1991, 86% of the Laguna Hills residents voted in favor of incorporation, and Laguna Hills officially became a city on December 20, 1991. The community of North Laguna Hills was annexed and incorporated in 1996, and in 2000, the Westside community of Laguna Hills was annexed and incorporated, adding 149 acres of residential land to the city (City of Laguna Hills 2024). Presently, Laguna Hills includes a population of about 31,000 residents. The economy is primarily comprised of professional, scientific, and technical service industries (Data USA 2024).

3.2 Development of La Paz Village
Commercial Complex
The La Paz Village commercial complex (Map IDs 1–4) was constructed in 1974 on previously undeveloped land surrounded by a partially developed residential neighborhood (Exhibit 1). At the time of its construction, prior to the incorporation of Laguna Hills as an independent city in 1991, the shopping complex was called the Mission Hills Plaza, and it was constructed at a cost of $2 million. City building permits indicated that Robert L. Kennedy owned the properties at the time of their construction; Kennedy was also listed as the builder of the commercial buildings.

There is no architect listed on the original building permits, and additional research did not identify the name of an architect associated with the development of the complex. Kennedy was the president of Mission Hills Realty Inc., a real estate development company active in Orange County during the 1970s. In addition to commercial properties, the company also developed and sold single-family residences and condominiums. It appears the company was relatively short lived, as Kennedy was convicted of income tax violations in 1980 (LAT 1974: 87; The Register 1976:
74; LAT 1980: 38).

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Exhibit 1. 1972 aerial photograph (left) showing the API partially developed; 1980 aerial photograph (right) showing the extant API (outlined in red)
Source: NETR 2024a
Several businesses have occupied the buildings since their construction. Research identifies the following businesses located at unspecified addresses within the La Paz Commercial Complex in 1975: Mission Hills Hair Fashions; Laguna Hills Pharmacy and Natural Vitamin Center; The Better Mouse Trap, a gift store with pottery; and Cornell's, a camera store (Press-Telegram 1975: 89).

In 1981, the shopping complex was expanded with the construction of a commercial building at 25552 La Paz Road (APN 620-211-19), located to the west of Map IDs 1–4. There are no additional discernible changes to the footprints and spatial configuration of the La Paz Village commercial complex since its construction (NETR 2024a).

The surrounding area was fully developed with residential and commercial development during the early 1980s.

The La Paz Village commercial complex is presently owned by the La Paz Village Investors LLC (ParcelQuest 2024; City of Laguna Hills City Clerk 2024).

3.3 Typology: Neighborhood Shopping Centers
(1950-1990)
After World War II, Americans, and particularly Southern Californians, became heavily reliant on automobile travel and were no longer restricted to shopping in downtown urban centers. New settlement patterns away from urban centers introduced new building types, including the neighborhood shopping center. Developers of this building type were able to dedicate more land for parking, which included clustering related stores around a generous amount of off-street parking. Typically, a neighborhood shopping center, which can be comprised of multiple buildings, was constructed at one time, which allowed for architectural continuity. In comparison to the earlier commercial blocks of independent shops, which varied in size, architectural style, and date of construction, neighborhood shopping centers had overall cohesion based on decisions made by the developer (Longstreth 1998, 2010; HRG 2007; Newman 1999).

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Neighborhood shopping centers were developed to be smaller than regional shopping centers (with department stores) and larger than strip malls. They featured one medium-sized anchor store, such as a grocery store or discount retailer, surrounded by smaller retailers. The neighborhood shopping center was typically oriented to a front parking lot and arranged in a straight L- or U-shaped pattern. This type of layout originated in the 1950s and was popularized in the 1970s (Longstreth 1998, 2010; City of LA 2017; Newman 1999).

Characteristics of the neighborhood shopping center typology:
 Primary entrances of stores off the parking lot
 Large surface parking lots surrounding the building(s)  Disconnection from the street
 Designed to appear as a single unit with a unifying design  One to two stories in height
 Box-like massing
 Located outside urban centers

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4 Results of Identification and
Evaluation Efforts
This section provides a physical description and an evaluation of each of the resources identified in the API under NRHP, CRHR, and local listing criteria to assess the historical significance and integrity of built resources in the API.

A physical description of each property and its development history are also provided below. The significance evaluations were prepared by Ms. Katie Ahmanson. Full DPRs that include more detailed information on the properties discussed below are available in Appendix B.

4.1 Survey Results
Five resources over 45 years of age at the time of survey were recorded and evaluated for historical significance.

These resources are summarized below in Table 3. Descriptions and evaluations of these resources are presented in Section 4.3 in order by Map ID.

Table 3. Built Environment Property Recorded in the API Map ID Property Type Address and APN Year Built
1a Commercial 25254 La Paz Road (APN 620-211-17) 1974
1b Commercial 25254 La Paz Road (APN 620-211-17) 1974
2 Commercial 25250 La Paz Road (APN 620-211-18) 1974
3 Commercial 25252 La Paz Road (APN 620-211-15) 1974
4 Commercial 25758 La Paz Road (APN 620-211-09) 1974
Note: APN = Assessor’s Parcel Number

4.2 Descriptions of Resources in the API
Property Description
The API is located on the southern side of La Paz Road on four parcels in the La Paz Village commercial complex:
25254 La Paz Road (APN 620-211-17), 25250 La Paz Road (APN 620-211-18), 25252 La Paz Road (APN 620- 211-15), and 25758 La Paz Road (APN 620-211-09). The API is relatively square in plan with five commercial buildings surrounded by asphalt parking lots. Map ID 2 is located along the northeast corner of the API, with Map ID 1a along the southern boundary of the API, and Map IDs 3, 1b, and 4 clustered together and set back from the northern boundary of the API (see Figure 2). Two concrete driveways provide access from La Paz Road and McIntyre Street. The API does not have any fences; landscaping includes sections of concrete planters with plantings and mature trees. Adjacent properties are developed with a one-story school to the south, one-story commercial buildings to the west and east, and one- and two-story residential buildings to the north and east.

Map ID 1a: 25254 La Paz Road (APN 620-211-17)
Map ID 1a was constructed in 1974. The commercial building is rectangular in plan and primarily one-story with a centralized two-story massing. The building features a flat roof with parapets atop the single-story wings, double-story massing with red-clay tile shed roofs with no overhang, and closed eaves supported by stone columns

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covering the pedestrian walkway along the north and east elevations of the building (Photograph 1). The exterior walls are primarily clad with painted stucco with stone cladding along the base of the elevations. Fenestration includes fully glazed, metal frame, single-leaf and double-leaf storefront doors and grouped, metal frame storefront windows. The building displays elements of the Spanish Colonial Revival architectural style, including simple rectangular massing, two-story height, a flat roof, red clay tile roofs with no overhang, and painted stucco cladding (Photograph 2).

The following list of known building alterations to Map ID 1a was compiled through City of Laguna Hills building permits and during the course of the intensive survey:
 1974: Establish a meat market and restaurant in basic building (Permit #264905)  2012: Americans with Disabilities Act exterior renovations (Permit #1-12-5389)  Date unknown: Replacement of storefronts (observed)
Photograph 1. Primary (north) elevation of Map ID 1a, view looking southwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_1627.JPG

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Photograph 2. Primary (north) and west elevations of Map ID 1a, view looking southeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_1648.JPG
Map ID 1b: 25254 La Paz Road (APN 620-211-17)
Map ID 1b was constructed in 1974. The commercial building is rectangular in plan and one story in height. It features a red-clay tile hipped roof with closed eaves and a flat roof section with a parapet (Photograph 3). The hipped roof primarily has no overhang; however, the roof has a wide overhang supported by stone clad columns along the primary (south) elevation that covers an outdoor courtyard enclosed with stone walls. The exterior walls are primarily clad with painted stucco with stone cladding along the base of the elevations. Fenestration includes fully glazed, metal frame, single-leaf and double-leaf storefront doors and grouped, metal frame storefront windows on the primary (south) and east elevations. The rear (north) elevation abuts the adjacent property, Map ID 4: 25758 La Paz Road (APN 620-211-09). The building displays elements of the Spanish Colonial Revival architectural style, including simple rectangular massing, one-story height, a red clay tile hipped roof with a flat roof section and minimal/no overhang, painted stucco cladding, and an outdoor courtyard (Photograph 4).

The City of Laguna Hills did not have any relevant building permits on file for Map ID 1b. The following list of known building alterations to Map ID 1b was compiled during the course of the intensive survey:
 Date unknown: Addition of awnings to primary (south) elevation (observed)  Date unknown: Replacement of storefronts (observed)

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Photograph 3. Primary (south) and west elevations of Map ID 1b, view looking northeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_1608.JPG
Photograph 4. Primary (south) and east elevations of Map ID 1b, view looking northwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_1614.JPG

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Map ID 2: 25250 La Paz Road (APN 620-211-18)
Map ID 2 was constructed in 1974. The commercial building is rectangular in plan and one story in height, with a flat roof featuring a parapet and red clay tile hipped roofs with no overhang, as well as closed eaves atop projecting rectangular volumes on all elevations (Photograph 5). The exterior walls are primarily clad with painted stucco and feature stone clad pilasters on all elevations. Additionally, the west and rear (north) elevations of the building feature a covered courtyard enclosed by a stone wall with stone columns supporting wood rafters (Photograph 6).

Fenestration includes fully-glazed, metal frame, single-leaf and double-leaf storefront doors, and grouped, metal frame storefront windows. The building displays elements of the Spanish Colonial Revival architectural style, including simple rectangular massing, one-story height, a flat roof, red clay tile hipped roofs with no overhang, painted stucco cladding, and an outdoor courtyard.

The following list of known building alterations to Map ID 2 was compiled through City of Laguna Hills building permits and during the course of the intensive survey:
 1974: Construct restaurant building (Permit #96443)
 2014: Tear down and rebuild 6,120 square feet (Permit #11-13-8234)  Date unknown: Addition of awnings (observed)
 Date unknown: Replacement of storefronts (observed)
Photograph 5. Primary (south) and west elevations of 25250 La Paz Road, view looking northeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_6712

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Photograph 6. East and rear (north) elevations of 25250 La Paz Road, view looking southeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_6722.JPG
Map ID 3: 25252 La Paz Road (APN 620-211-15)
Map ID 3 was constructed in 1974. The commercial building is rectangular in plan, one story in height, and features a flat roof with a parapet (Photograph 7). The exterior walls are primarily clad with painted stucco and include vertical wood board cladding on the primary (north), west, and east elevations. The primary (north) elevation is asymmetrical with a projecting rectangular massing, and a wood flat roof supported by wood posts extending from the elevation. The primary entry door is recessed and features a single leaf, fully glazed, metal frame storefront door. Fenestration on the primary (north), east, and west elevations include grouped, metal frame storefront windows with a metal frame casement drive-thru window located on the east elevation beneath the projecting hipped roof. Additionally, the rear (south) elevation features two attached ancillary sheds (Photograph 8). The following list of known building alterations to Map ID 3 was compiled through City of Laguna Hills building permits and during the course of the intensive survey:
 1974: Construct “drive-in restaurant” (Permit #92941
 1993: Enclose existing outdoor seating (Permit #0833)  2001: Reroof (Permit #12969)
 2005: 1,104 square feet of new facade and the addition of a 260-square-foot patio (Permit #20005-0372)  2015: Tear off flat roof and install four-play hot mop (Permit #9020)  2024: New outdoor gathering space, upgraded building accessibility, a new entry portal, new exterior cladding, and new landscaping (Permit #0002-2024)
 Date unknown: Removal of hipped red clay tile roofs from tower volume and a drive-through window on the east elevation (observed)

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 Date unknown: Replacement of storefronts (observed)
Photograph 7. Primary (north) and east elevations of 25252 La Paz Road, view looking southwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_1568.JPG
Photograph 8. East and rear (south) elevations of 25252 La Paz Road, view looking northwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_6736.JPG

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Map ID 4: 25758 La Paz Road (APN 620-211-09)
Map ID 4 was constructed in 1974. The commercial building is rectangular in plan and one story in height, with two massings each featuring a red-clay tile hipped roof with closed eaves and minimal overhangs, and a flat roof section with a parapet (Photograph 9). The exterior walls featuring a combination of cladding, including brick veneers along the primary (north) elevation and painted stucco cladding on the east, rear (south), and west elevations.

Fenestration includes fully-glazed, metal frame, single-leaf and double-leaf storefront doors, and grouped, metal frame storefront windows on the primary (north) and west elevations. The rear (south) elevation abuts the adjacent property, Map ID 3b: 25254 La Paz Road (APN 620-211-17). The building displays elements of the Spanish Colonial Revival architectural style, including simple rectangular massing, one-story height, a red clay tile hipped roof with a flat roof section and minimal overhang, and painted stucco cladding (Photograph 10). The following list of known building alterations to Map ID 4 was compiled through City of Laguna Hills building permits and during the course of the intensive survey:
 1992: Reroof (Permit # NR9202240009)
 Date unknown: Replacement of storefronts (observed)
Photograph 9. Primary (north) and west elevations of Map ID 4, view looking southeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_1584.JPG

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Photograph 10. Primary (north) and east elevations of Map ID 4, view looking southwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_1570.JPG

4.3 Statement of Significance
For a property to be listed in, or determined eligible for listing in the NRHP, it must first be demonstrated to possess significance by meeting at least one of four criteria. In addition to possessing significance, an eligible or listed property must retain its physical integrity. The CRHR was designed to reflect the same criteria and integrity as those identified for the NRHP. Therefore, the NRHP and CRHR significance evaluations are presented together.

NRHP and CRHR Evaluation
Under NRHP Criterion A and CRHR Criterion 1, the buildings identified as Map IDs 1a ,1b, 2, 3, and 4 lack a direct and important association with any event significant in local, state, or national history. Map IDs 1–4 were constructed in 1974 as part of a shopping center originally called the Mission Hills Plaza (today, called La Paz Village). The subject properties share an association with the trends of commercial growth in Laguna Hills during the 1950s through the 1970s, but they did not contribute in any significant way to those trends. In Laguna Hills, the statewide factors causing population growth following World War II’s conclusion in 1945 were exacerbated by the subdivision of Moulton Ranch in the early 1950s, which brought many new residents to the area. By the late 1960s, the Mission Viejo Company developed much of the surrounding area; as a result, commercial development increased during this period, including shopping centers such as the subject property, the Laguna Hills Plaza (1970), the Laguna Hills Mall (1973), and the Wild West Plaza (1974). As a commercial property constructed in 1974, the subject property represents this trend of post-World War II commercial expansion. While this is an important trend both regionally and statewide, the subject property did not play a significant role in this trend, nor did it influence this trend. It was one of many commercial properties constructed in Laguan Hills during this period.

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According to archival research, there is no indication it is associated with events that have made a significant contribution to broad patterns of history. For these reasons, the subject properties do not appear eligible under NRHP Criterion A or CRHR Criterion 1.

Under NRHP Criterion B and CRHR Criterion 2, the buildings identified as Map IDs 1a, 1b, 2, 3, and 4 lack a direct and significant association with the productive life of any person considered important in history. Map IDs 1–4 were built by their original owner, Robert L. Kennedy. Kennedy was the president of Mission Hills Realty Inc. and developed commercial and residential properties in Orange County in during the 1970s before his company dissolved in 1980. The subject properties have continued to function as a local shopping center with various business occupying the buildings since their construction. Presently, the La Paz Village commercial complex is owned by La Paz Village Investors LLC (ParcelQuest 2024). Research did not yield further information about Kennedy or the La Paz Village Investors LLC, and did not indicate that the subject properties have been associated with the life of a significant individual. Due to a lack of identified significant associations with important individuals, the subject properties do not appear eligible under NRHP Criterion B or CRHR Criterion 2.

Under NRHP Criterion C and CRHR Criterion 3, the buildings identified as Map IDs 1a, 1b, 2, 3, and 4 lack design and construction value because they do not possess architectural distinction or high artistic value, and do represent the work of a master or contribute to the significance of a district. The five commercial buildings all represent undifferentiated, largely unembellished, commercial buildings. The buildings are undistinguished examples of commercial architecture as applied to the neighborhood shopping center property type. The subject properties reflect several characteristics of the neighborhood shopping center typology, including primary entrances of stores off the parking lot, large surface parking lots surrounding the buildings, disconnection from the street, one story in height, and boxlike massing. However, the subject properties are not significant examples of the property type in Laguna Hills or Orange County. Rather, the subject properties represent a common example of a 1970s commercial shopping center. Additionally, the buildings no longer represent a unifying design due to multiple alterations over the years that have inhibited their ability to reflect their historic design. These buildings reflect ubiquitous building trends from the period with rectangular plans, primarily painted stucco cladding, and parking lots surrounding the buildings. There are better and more intact examples of the 1970s neighborhood shopping centers throughout Laguna Hills, Orange County, and California. Original building permits for the subject properties indicate the original owner, Robert Kennedy, was listed as the builder of the properties. Although Kennedy was the president of Mission Hills Inc., he does not appear to be a significant builder. As such, the buildings lack sufficient distinctive characteristics of a type, period, or method of construction; do not represent the work of a master; do not possess high artistic values; nor do they appear to be potential contributors to a historic district. Therefore, the subject properties do not appear eligible under NRHP Criterion C or CRHR Criterion 3.

Under NRHP Criterion D and CRHR Criterion 4, the La Paz Village commercial complex is not significant as a source, or likely source, of important historical information, nor does it appear likely to yield important information about historic construction methods, materials, or technologies. This technology is well understood through contemporary trade journals and scientific monographs. As such, the subject property lacks significance under NRHP Criterion D and CRHR Criterion 4.

Integrity Assessment
Integrity is the ability of a property to convey its significance. Because the concept of integrity is based on significance, the assessment of a property’s integrity can only proceed after its significance has been fully established. The assessment of integrity requires consideration under the seven aspects or qualities. To retain

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integrity, a property will always possess several, and generally most, aspects of integrity. Determining which aspects are most important requires an understanding of why, where, and when the property is significant. Because the subject property evaluated in this report lack sufficient significance to meet any of the criteria for listing in the NRHP or CRHR, an integrity analysis was considered immaterial for the subject properties.

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5 Findings and Conclusions
The subject properties were evaluated in consideration of NRHP and CRHR criteria and integrity requirements. As a result of the evaluation, Map ID 1a (25254 La Paz Road), Map ID 1b (25254 La Paz Road), Map ID 3 (25252 La Paz Road), Map ID 2 (25250 La Paz Road), and Map ID 4 (25758 La Paz Road) are recommended as ineligible for inclusion in the NRHP and CRHR.

No historical resources or historic properties were identified within the API as a result of archival research, a SCCIC records search, field survey, and significance evaluations. The subject properties are not currently listed in any national, state, or local registers, nor have they been previously identified in any local historic resources surveys.

Dudek evaluated the resources in the API in accordance with Section 15064.5 (a)(2)–(3) of the CEQA Guidelines using the criteria outlined in Section 5024.1 of the California PRC and found that none of the resources within the API are considered historical resources for the purposes of CEQA. The recommended Status Code for Map IDs 1a, 1b, 2, 3, and 4 is 6Z. A summary of the findings is provided below in Table 4.

Table 4. Summary of Significance Evaluation Findings
Map ID Property Type Address and APN Year Built
California Historical
Resource Status
code NRHP/CRHR
1a Commercial 25254 La Paz Road
(APN 620-211-17)
1974 6Z Not Eligible
1b Commercial 25254 La Paz Road
(APN 620-211-17)
1974 6Z Not Eligible
2 Commercial 25250 La Paz Road
(APN 620-211-18)
1974 6Z Not Eligible
3 Commercial 25252 La Paz Road
(APN 620-211-15)
1974 6Z Not Eligible
4 Commercial 25758 La Paz Road
(APN 620-211-09)
1974 6Z Not Eligible
Notes: APN = Assessor’s Parcel Number; NRHP = National Register of Historic Places; CRHR = California Register of Historical Resources; 6Z = Found ineligible for National Register, California Register, or local designation through survey evaluation

LA PAZ VILLAGE SENIOR HOUSING PROJECT, LAGUNA HILLS, ORANGE COUNTY, CALIFORNIA / BUILT

ENVIRONMENT INVENTORY AND EVALUATION REPORT
15408.02 34
FEBRUARY 2025

INTENTIONALLY LEFT BLANK

15408.02 35
FEBRUARY 2025
6 References
AB (Anaheim Bulletin). 1969. "Historic Swartz Farm Site to Become Shopping Center." June 14, 1969. Anaheim Bulletin (Newspapers.com: Anaheim, California). Page 31.

City of Laguna Hills. 2024. “History of Laguna Hills.” Laguna Hills, California: City of Laguna Hills. Accessed July 19, 2024. https://www.ci.laguna-hills.ca.us/247/History-of-Laguna-Hills.

City of Laguna Hills City Clerk. 2024. Building Permits. Laguna Hills, California: City of Laguna Hills. Received July 24, 2024.

City of Laguna Niguel. 2024. “History.” Laguna Niguel, California: City of Laguna Niguel. Accessed July 19, 2024. https://www.cityoflagunaniguel.org/388/History.

CD (Coastline Dispatch). 1964. "Mission Viejo Project Gets Okay of Planners." June 17, 1964. Coastline Dispatch (Newspapers.com: San Juan Capistrano, California). Page 1.

CD. 1972. "Four Major Department Stores Tagged For Laguna Hills Mall." May 31, 1972. Coastline Dispatch (Newspapers.com: San Juan Capistrano, California). Page 7.

Data USA. 2024. “Laguna Hills.” United States Census Bureau. Accessed July 22, 2024. https://datausa.io/ profile/geo/laguna-hills-ca/.

HRG (Historic Resources Group). 2007. Cultural Resources of the Recent Past Historic Context Report. Pasadena, California: City of Pasadena.

LAT (Los Angeles Times). 1974. "Shopping Centers." July 28, 1974. Los Angeles Times (Newspapers.com:

Los Angeles, California). Page 87.

LAT. 1980. "Three Convicted on Income Tax Counts." June 27, 1980. Los Angeles Times (Newspapers.com:

Los Angeles, California). Page 38.

LAT. 1989. “Laguna: Voters Reject Cityhood.” Newspapers.com: Los Angeles Times (Newspapers.com:

Los Angeles, California). June 7, 1989. Page 51.

Longstreth, Richard. 1998. City Center to Regional Mall: Architecture, the Automobile, and Retailing in Los Angeles, 1920-1950. Cambridge, Massachusetts: The MIT Press.

Longstreth, Richard. 2010. The American Department Store Transformed, 1920-1960. New Haven, Connecticut:

Yale University Press.

Moulton Museum. 2024. “Mission and History.” Laguna Hills, California: Moulton Museum. Accessed August 26, 2024. https://moultonmuseum.org/about-mission-and-history/.

LA PAZ VILLAGE SENIOR HOUSING PROJECT, LAGUNA HILLS, ORANGE COUNTY, CALIFORNIA / BUILT

ENVIRONMENT INVENTORY AND EVALUATION REPORT
15408.02 36
FEBRUARY 2025
NPS (National Park Service). 1995. National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. Washington, DC: Department of the Interior, Government Printing Office. https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf.

NETR (Nationwide Environmental Title Research LLC). 2024a. “Historic Aerial Photographs of La Paz Village, Laguna Hills, Orange County, CA, dating from 1938, 1946, 1952, 1967, 1972, 1980, 1981, 1985, 1987, 1988, 1992, 1993, 1994, 1995, 1996, 1997, 1998, 1999, 2000, 2002, 2003, 2004, 2005, 2009, 2010, 2012, 2014, 2016, 2018, and 2020” [map]. Accessed July 18, 2024. https://www.historicaerials.com/viewer.

NETR. 2024b. “Historic Topographic Maps of La Paz Village, Laguna Hills, Orange County, CA, dating from 1949, 1957, 1960, 1963, 1965, 1969, 1977, 1981, 2012, 2015, 2018, and 2022” [map]. Accessed July 18, 2024. https://www.historicaerials.com/viewer.

Newman, Morris. 1999. “In Rise and Fall of Malls, Weaker Ones Get Demalled.” Los Angeles Times (Los Angeles, California). December 14, 1999. https://www.latimes.com/archives/la-xpm-1999-dec-14-mn-43909- story.html.

ParcelQuest. 2024. “APNs: 620-211-15, 620-211-18, 620-211-17, and 620-211-09” [map]. ParcelQuest.

Accessed July 22, 2024. https://pqweb.parcelquest.com/#home.

Press-Telegram. 1975. "Classified - Newcomers Welcome to the Wild West Plaza." August 31, 1975. PressTelegram (Long Beach, California). Page 89.

SPN (Sun Post News). 1974. "Advertisements." July 3, 1974. Sun Post News (Newspapers.com: San Clemente, California). Page 8.

The Register. 1976. "Classified - Laguna Hills." August 22, 1976. The Register (Newspapers.com: Santa Ana, California). Page 74.

Appendix A
Interested Party Correspondence

From: Katie Ahmanson
To: [email protected]
Cc: Claire Cancilla
Subject: La Paz Village Senior Housing Project - Laguna Hills Historical Society Outreach Date: Thursday, July 25, 2024 1:20:00 PM
Attachments: image001.png
image002.png
image003.png
image004.png
image005.png
Laguna Hills Historical Society_Outreach Letter.pdf
To Whom it May Concern,
I am reaching out today on behalf of Dudek and the City of Laguna Hills to provide you with some information about the La Paz Village Senior Housing Project. As part of the cultural resources study for the proposed project, Dudek is consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be within the proposed project area. Please see the attached letter and maps for more information about the nature and location of the project, and please feel free to contact me should you have questions or information regarding cultural or historical resources in this area.

Thank you,
Katie Ahmanson
Katie Ahmanson (she/her) O: 626 204 9807
Architectural Historian dudek.com

Laguna Hills Historical Society July 25, 2024
30025 Alicia Parkway #190
Laguna Niguel, CA 92677

Subject: La Paz Village Senior Housing Project, Laguna Hills, Orange County, California To Whom it May Concern,
Dudek has been retained by the City of Laguana Hills (City) to assess and disclose the potential impacts on the environment of the La Paz Village Senior Housing Project (Proposed Project). The Proposed Project is located in Laguna Hills, Orange County, and includes four properties constructed in 1974. These properties are as follows (see Figure 1 and Figure 2 enclosed):
 25252 La Paz Road (APN 620-211-15)
 25250 La Paz Road (APN 620-211-18)
 25254 La Paz Road (APN 620-211-17)
 25758 La Paz Road (APN 620-211-09)
The City is proposing to demolish 25252 La Paz Road (APN 620-211-15), 25250 La Paz Road (APN 620-211-18), and 25254 La Paz Road (APN 620-211-17) for the construction of a senior housing. The proposed development would be up to five stories and would include 180 age-restricted units, of which 144 would be market rate and 36 would be affordable units, along with 255 parking spaces in a parking garage on the basement and at-grade parking on the first level. As part of our study, we are consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be affected by the Proposed Project. Your efforts in this process will provide invaluable information for the proper identification and treatment of such resources. If you have any information regarding known cultural resources in the Proposed Project area, please feel free to contact me via phone or email (listed below). All comments, emails, or letters received will be included in the reports generated by this study. Thank you for your time regarding our request.

Sincerely,
____________________________________
Katie Ahmanson, MHC
Architectural Historian
323.829.9088 / [email protected]
Att.: Figure 1, Project Location
Figure 2, Built Environment API
Cc: Claire Cancilla, MSHP, Dudek

Project Site
0 1,000 2,000
n Feet Date: 7/25/2024 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Project Location Layout: Figure1_ProjectLocation San Clemente
Dana Point
San Juan Capistrano
Laguna Niguel
Rancho
Santa
Margarita
Mission Viejo
Lake
Forest Huntington
Beach Irvine
Garden
Grove
Cypress Orange
Murrieta
Lake
Elsinore
Menifee
Perris
Perris
Corona
Long
Beach
Chino
Hills
Riverside
Newport
Beach
Tustin
ÄÆ57
ÄÆ73
ÄÆ91
ÄÆ22
ÄÆ55
ÄÆ90
ÄÆ241
ÄÆ133
ÄÆ39
ÄÆ74
§¨¦5
§¨¦405
§¨¦605
§¨¦15
S a n D i e g o
C o u n t y
O r a n g e
C o u n t y
R i v e r s i d e
C o u n t y
Project Site
!(
^
SOURCE: USGS 7.5 Minute Series
La Paz Village Senior Housing
Project Location
FIGURE 1

La Paz Rd
Sycamore Ln
Rickenbacker Rd
Mackenzie St
McIntyre St
Map ID 3a
Map ID 2
Map ID 3b
Map
ID 1
Map ID 4
Project Site
Area of Potential Impacts
Map IDs
Map ID 1: 25252 La Paz Road (APN 620-211-15)
Map ID 2: 25250 La Paz Road (APN 620-211-18)
Map ID 3a: 25254 La Paz Road (APN 620-211-17)
Map ID 3b: 25254 La Paz Road (APN 620-211-17)
Map ID 4: 25758 La Paz Road (APN 620-211-09)
0 40 80 n Feet Date: 7/25/2024 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Figure2_BuiltEnvironmentAreaofPotentialImpacts Layout: Figure2_BuiltEnvironmentAreaofPotentialImpacts SOURCE: Esri World Imagery 2023
La Paz Village Senior Housing Project
Built Environment Area of Potential Impacts
FIGURE 2

From: Katie Ahmanson
To: [email protected]
Cc: Claire Cancilla
Subject: La Paz Village Senior Housing Project - Laguna Hills Technology Library Outreach Date: Thursday, July 25, 2024 1:20:00 PM
Attachments: image001.png
image002.png
image003.png
image004.png
image005.png
Laguna Hills Technology Library _Outreach Letter.pdf
To Whom it May Concern,
I am reaching out today on behalf of Dudek and the City of Laguna Hills to provide you with some information about the La Paz Village Senior Housing Project. As part of the cultural resources study for the proposed project, Dudek is consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be within the proposed project area. Please see the attached letter and maps for more information about the nature and location of the project, and please feel free to contact me should you have questions or information regarding cultural or historical resources in this area.

Thank you,
Katie Ahmanson
Katie Ahmanson (she/her) O: 626 204 9807
Architectural Historian dudek.com

Laguna Hills Technology Library July 25, 2024
25555 Alicia Parkway
Laguna Hills, CA 92653

Subject: La Paz Village Senior Housing Project, Laguna Hills, Orange County, California To Whom it May Concern,
Dudek has been retained by the City of Laguana Hills (City) to assess and disclose the potential impacts on the environment of the La Paz Village Senior Housing Project (Proposed Project). The Proposed Project is located in Laguna Hills, Orange County, and includes four properties constructed in 1974. These properties are as follows (see Figure 1 and Figure 2 enclosed):
 25252 La Paz Road (APN 620-211-15)
 25250 La Paz Road (APN 620-211-18)
 25254 La Paz Road (APN 620-211-17)
 25758 La Paz Road (APN 620-211-09)
The City is proposing to demolish 25252 La Paz Road (APN 620-211-15), 25250 La Paz Road (APN 620-211-18), and 25254 La Paz Road (APN 620-211-17) for the construction of a senior housing. The proposed development would be up to five stories and would include 180 age-restricted units, of which 144 would be market rate and 36 would be affordable units, along with 255 parking spaces in a parking garage on the basement and at-grade parking on the first level. As part of our study, we are consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be affected by the Proposed Project. Your efforts in this process will provide invaluable information for the proper identification and treatment of such resources. If you have any information regarding known cultural resources in the Proposed Project area, please feel free to contact me via phone or email (listed below). All comments, emails, or letters received will be included in the reports generated by this study. Thank you for your time regarding our request.

Sincerely,
____________________________________
Katie Ahmanson, MHC
Architectural Historian
323.829.9088 / [email protected]
Att.: Figure 1, Project Location
Figure 2, Built Environment API
Cc: Claire Cancilla, MSHP, Dudek

Project Site
0 1,000 2,000
n Feet Date: 7/25/2024 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Project Location Layout: Figure1_ProjectLocation San Clemente
Dana Point
San Juan Capistrano
Laguna Niguel
Rancho
Santa
Margarita
Mission Viejo
Lake
Forest Huntington
Beach Irvine
Garden
Grove
Cypress Orange
Murrieta
Lake
Elsinore
Menifee
Perris
Perris
Corona
Long
Beach
Chino
Hills
Riverside
Newport
Beach
Tustin
ÄÆ57
ÄÆ73
ÄÆ91
ÄÆ22
ÄÆ55
ÄÆ90
ÄÆ241
ÄÆ133
ÄÆ39
ÄÆ74
§¨¦5
§¨¦405
§¨¦605
§¨¦15
S a n D i e g o
C o u n t y
O r a n g e
C o u n t y
R i v e r s i d e
C o u n t y
Project Site
!(
^
SOURCE: USGS 7.5 Minute Series
La Paz Village Senior Housing
Project Location
FIGURE 1

La Paz Rd
Sycamore Ln
Rickenbacker Rd
Mackenzie St
McIntyre St
Map ID 3a
Map ID 2
Map ID 3b
Map
ID 1
Map ID 4
Project Site
Area of Potential Impacts
Map IDs
Map ID 1: 25252 La Paz Road (APN 620-211-15)
Map ID 2: 25250 La Paz Road (APN 620-211-18)
Map ID 3a: 25254 La Paz Road (APN 620-211-17)
Map ID 3b: 25254 La Paz Road (APN 620-211-17)
Map ID 4: 25758 La Paz Road (APN 620-211-09)
0 40 80 n Feet Date: 7/25/2024 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Figure2_BuiltEnvironmentAreaofPotentialImpacts Layout: Figure2_BuiltEnvironmentAreaofPotentialImpacts SOURCE: Esri World Imagery 2023
La Paz Village Senior Housing Project
Built Environment Area of Potential Impacts
FIGURE 2

From: Katie Ahmanson
To: "[email protected]"
Cc: Claire Cancilla
Subject: La Paz Village Senior Housing Project - Laguna Woods History Center Outreach Date: Thursday, July 25, 2024 1:20:00 PM
Attachments: image001.png
image002.png
image003.png
image004.png
image005.png
Laguna Woods History Center_Outreach Letter.pdf
To Whom it May Concern,
I am reaching out today on behalf of Dudek and the City of Laguna Hills to provide you with some information about the La Paz Village Senior Housing Project. As part of the cultural resources study for the proposed project, Dudek is consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be within the proposed project area. Please see the attached letter and maps for more information about the nature and location of the project, and please feel free to contact me should you have questions or information regarding cultural or historical resources in this area.

Thank you,
Katie Ahmanson
Katie Ahmanson (she/her) O: 626 204 9807
Architectural Historian dudek.com

Laguna Woods History Center July 25, 2024
P.O. Box 2220
Laguna Hills, CA 92654

Subject: La Paz Village Senior Housing Project, Laguna Hills, Orange County, California To Whom it May Concern,
Dudek has been retained by the City of Laguana Hills (City) to assess and disclose the potential impacts on the environment of the La Paz Village Senior Housing Project (Proposed Project). The Proposed Project is located in Laguna Hills, Orange County, and includes four properties constructed in 1974. These properties are as follows (see Figure 1 and Figure 2 enclosed):
 25252 La Paz Road (APN 620-211-15)
 25250 La Paz Road (APN 620-211-18)
 25254 La Paz Road (APN 620-211-17)
 25758 La Paz Road (APN 620-211-09)
The City is proposing to demolish 25252 La Paz Road (APN 620-211-15), 25250 La Paz Road (APN 620-211-18), and 25254 La Paz Road (APN 620-211-17) for the construction of a senior housing. The proposed development would be up to five stories and would include 180 age-restricted units, of which 144 would be market rate and 36 would be affordable units, along with 255 parking spaces in a parking garage on the basement and at-grade parking on the first level. As part of our study, we are consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be affected by the Proposed Project. Your efforts in this process will provide invaluable information for the proper identification and treatment of such resources. If you have any information regarding known cultural resources in the Proposed Project area, please feel free to contact me via phone or email (listed below). All comments, emails, or letters received will be included in the reports generated by this study. Thank you for your time regarding our request.

Sincerely,
____________________________________
Katie Ahmanson, MHC
Architectural Historian
323.829.9088 / [email protected]
Att.: Figure 1, Project Location
Figure 2, Built Environment API
Cc: Claire Cancilla, MSHP, Dudek

Project Site
0 1,000 2,000
n Feet Date: 7/25/2024 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Project Location Layout: Figure1_ProjectLocation San Clemente
Dana Point
San Juan Capistrano
Laguna Niguel
Rancho
Santa
Margarita
Mission Viejo
Lake
Forest Huntington
Beach Irvine
Garden
Grove
Cypress Orange
Murrieta
Lake
Elsinore
Menifee
Perris
Perris
Corona
Long
Beach
Chino
Hills
Riverside
Newport
Beach
Tustin
ÄÆ57
ÄÆ73
ÄÆ91
ÄÆ22
ÄÆ55
ÄÆ90
ÄÆ241
ÄÆ133
ÄÆ39
ÄÆ74
§¨¦5
§¨¦405
§¨¦605
§¨¦15
S a n D i e g o
C o u n t y
O r a n g e
C o u n t y
R i v e r s i d e
C o u n t y
Project Site
!(
^
SOURCE: USGS 7.5 Minute Series
La Paz Village Senior Housing
Project Location
FIGURE 1

La Paz Rd
Sycamore Ln
Rickenbacker Rd
Mackenzie St
McIntyre St
Map ID 3a
Map ID 2
Map ID 3b
Map
ID 1
Map ID 4
Project Site
Area of Potential Impacts
Map IDs
Map ID 1: 25252 La Paz Road (APN 620-211-15)
Map ID 2: 25250 La Paz Road (APN 620-211-18)
Map ID 3a: 25254 La Paz Road (APN 620-211-17)
Map ID 3b: 25254 La Paz Road (APN 620-211-17)
Map ID 4: 25758 La Paz Road (APN 620-211-09)
0 40 80 n Feet Date: 7/25/2024 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Figure2_BuiltEnvironmentAreaofPotentialImpacts Layout: Figure2_BuiltEnvironmentAreaofPotentialImpacts SOURCE: Esri World Imagery 2023
La Paz Village Senior Housing Project
Built Environment Area of Potential Impacts
FIGURE 2

From: Katie Ahmanson
To: [email protected]
Cc: Claire Cancilla
Subject: La Paz Village Senior Housing Project - Laguna Woods Village Library Outreach Date: Thursday, July 25, 2024 1:20:00 PM
Attachments: image001.png
image002.png
image003.png
image004.png
image005.png
Laguna Woods Village Library _Outreach Letter.pdf
To Whom it May Concern,
I am reaching out today on behalf of Dudek and the City of Laguna Hills to provide you with some information about the La Paz Village Senior Housing Project. As part of the cultural resources study for the proposed project, Dudek is consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be within the proposed project area. Please see the attached letter and maps for more information about the nature and location of the project, and please feel free to contact me should you have questions or information regarding cultural or historical resources in this area.

Thank you,
Katie Ahmanson
Katie Ahmanson (she/her) O: 626 204 9807
Architectural Historian dudek.com

Laguna Woods Village Library July 25, 2024
24266 Calle Aragon
Laguna Woods, CA 92637

Subject: La Paz Village Senior Housing Project, Laguna Hills, Orange County, California To Whom it May Concern,
Dudek has been retained by the City of Laguana Hills (City) to assess and disclose the potential impacts on the environment of the La Paz Village Senior Housing Project (Proposed Project). The Proposed Project is located in Laguna Hills, Orange County, and includes four properties constructed in 1974. These properties are as follows (see Figure 1 and Figure 2 enclosed):
 25252 La Paz Road (APN 620-211-15)
 25250 La Paz Road (APN 620-211-18)
 25254 La Paz Road (APN 620-211-17)
 25758 La Paz Road (APN 620-211-09)
The City is proposing to demolish 25252 La Paz Road (APN 620-211-15), 25250 La Paz Road (APN 620-211-18), and 25254 La Paz Road (APN 620-211-17) for the construction of a senior housing. The proposed development would be up to five stories and would include 180 age-restricted units, of which 144 would be market rate and 36 would be affordable units, along with 255 parking spaces in a parking garage on the basement and at-grade parking on the first level. As part of our study, we are consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be affected by the Proposed Project. Your efforts in this process will provide invaluable information for the proper identification and treatment of such resources. If you have any information regarding known cultural resources in the Proposed Project area, please feel free to contact me via phone or email (listed below). All comments, emails, or letters received will be included in the reports generated by this study. Thank you for your time regarding our request.

Sincerely,
____________________________________
Katie Ahmanson, MHC
Architectural Historian
323.829.9088 / [email protected]
Att.: Figure 1, Project Location
Figure 2, Built Environment API
Cc: Claire Cancilla, MSHP, Dudek

Project Site
0 1,000 2,000
n Feet Date: 7/25/2024 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Project Location Layout: Figure1_ProjectLocation San Clemente
Dana Point
San Juan Capistrano
Laguna Niguel
Rancho
Santa
Margarita
Mission Viejo
Lake
Forest Huntington
Beach Irvine
Garden
Grove
Cypress Orange
Murrieta
Lake
Elsinore
Menifee
Perris
Perris
Corona
Long
Beach
Chino
Hills
Riverside
Newport
Beach
Tustin
ÄÆ57
ÄÆ73
ÄÆ91
ÄÆ22
ÄÆ55
ÄÆ90
ÄÆ241
ÄÆ133
ÄÆ39
ÄÆ74
§¨¦5
§¨¦405
§¨¦605
§¨¦15
S a n D i e g o
C o u n t y
O r a n g e
C o u n t y
R i v e r s i d e
C o u n t y
Project Site
!(
^
SOURCE: USGS 7.5 Minute Series
La Paz Village Senior Housing
Project Location
FIGURE 1

La Paz Rd
Sycamore Ln
Rickenbacker Rd
Mackenzie St
McIntyre St
Map ID 3a
Map ID 2
Map ID 3b
Map
ID 1
Map ID 4
Project Site
Area of Potential Impacts
Map IDs
Map ID 1: 25252 La Paz Road (APN 620-211-15)
Map ID 2: 25250 La Paz Road (APN 620-211-18)
Map ID 3a: 25254 La Paz Road (APN 620-211-17)
Map ID 3b: 25254 La Paz Road (APN 620-211-17)
Map ID 4: 25758 La Paz Road (APN 620-211-09)
0 40 80 n Feet Date: 7/25/2024 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Figure2_BuiltEnvironmentAreaofPotentialImpacts Layout: Figure2_BuiltEnvironmentAreaofPotentialImpacts SOURCE: Esri World Imagery 2023
La Paz Village Senior Housing Project
Built Environment Area of Potential Impacts
FIGURE 2

From: Katie Ahmanson
To: [email protected]
Cc: Claire Cancilla
Subject: La Paz Village Senior Housing Project - Orange County Historical Society Outreach Date: Thursday, July 25, 2024 1:20:00 PM
Attachments: image001.png
image002.png
image003.png
image004.png
image005.png
Orange County Historical Society_Outreach Letter.pdf
To Whom it May Concern,
I am reaching out today on behalf of Dudek and the City of Laguna Hills to provide you with some information about the La Paz Village Senior Housing Project. As part of the cultural resources study for the proposed project, Dudek is consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be within the proposed project area. Please see the attached letter and maps for more information about the nature and location of the project, and please feel free to contact me should you have questions or information regarding cultural or historical resources in this area.

Thank you,
Katie Ahmanson
Katie Ahmanson (she/her) O: 626 204 9807
Architectural Historian dudek.com

Orange County Historical Society July 25, 2024
3101 W Harvard Street
Santa Ana, CA 92704

Subject: La Paz Village Senior Housing Project, Laguna Hills, Orange County, California To Whom it May Concern,
Dudek has been retained by the City of Laguana Hills (City) to assess and disclose the potential impacts on the environment of the La Paz Village Senior Housing Project (Proposed Project). The Proposed Project is located in Laguna Hills, Orange County, and includes four properties constructed in 1974. These properties are as follows (see Figure 1 and Figure 2 enclosed):
 25252 La Paz Road (APN 620-211-15)
 25250 La Paz Road (APN 620-211-18)
 25254 La Paz Road (APN 620-211-17)
 25758 La Paz Road (APN 620-211-09)
The City is proposing to demolish 25252 La Paz Road (APN 620-211-15), 25250 La Paz Road (APN 620-211-18), and 25254 La Paz Road (APN 620-211-17) for the construction of a senior housing. The proposed development would be up to five stories and would include 180 age-restricted units, of which 144 would be market rate and 36 would be affordable units, along with 255 parking spaces in a parking garage on the basement and at-grade parking on the first level. As part of our study, we are consulting all regional historical organizations to determine if there are any known historic or cultural resources that may be affected by the Proposed Project. Your efforts in this process will provide invaluable information for the proper identification and treatment of such resources. If you have any information regarding known cultural resources in the Proposed Project area, please feel free to contact me via phone or email (listed below). All comments, emails, or letters received will be included in the reports generated by this study. Thank you for your time regarding our request.

Sincerely,
____________________________________
Katie Ahmanson, MHC
Architectural Historian
323.829.9088 / [email protected]
Att.: Figure 1, Project Location
Figure 2, Built Environment API
Cc: Claire Cancilla, MSHP, Dudek

Project Site
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SOURCE: USGS 7.5 Minute Series
La Paz Village Senior Housing
Project Location
FIGURE 1

La Paz Rd
Sycamore Ln
Rickenbacker Rd
Mackenzie St
McIntyre St
Map ID 3a
Map ID 2
Map ID 3b
Map
ID 1
Map ID 4
Project Site
Area of Potential Impacts
Map IDs
Map ID 1: 25252 La Paz Road (APN 620-211-15)
Map ID 2: 25250 La Paz Road (APN 620-211-18)
Map ID 3a: 25254 La Paz Road (APN 620-211-17)
Map ID 3b: 25254 La Paz Road (APN 620-211-17)
Map ID 4: 25758 La Paz Road (APN 620-211-09)
0 40 80 n Feet Date: 7/25/2024 User: cgardner Path: Z:\Projects\j1540802\MAPDOC\LaPazSeniorHousing\LaPazSeniorHousing.aprx Map: Figure2_BuiltEnvironmentAreaofPotentialImpacts Layout: Figure2_BuiltEnvironmentAreaofPotentialImpacts SOURCE: Esri World Imagery 2023
La Paz Village Senior Housing Project
Built Environment Area of Potential Impacts
FIGURE 2

Appendix B
DPR Form

*P11. Report Citation: (Cite survey report and other sources, or enter "none.") Dudek. 2024. La Paz Village Senior Housing Project, Laguna Hills, Orange County, California Built Environment Inventory and Evaluation Report. Prepared for City of Laguna Hills.
*Attachments: ☐ NONE ☒Location Map ☒Continuation Sheet ☒Building, Structure, and Object Record ☐Archaeological Record ☐District Record ☐Linear Feature Record ☐Milling Station Record ☐Rock Art Record ☐Artifact Record ☐Photograph Record ☐Sketch Map ☐Other (List):

DPR 523A *Required Information
State of California - The Resources Agency Primary #
DEPARTMENT OF PARKS AND RECREATION HRI #
PRIMARY RECORD Trinomial
NRHP Status Code 6Z
Other Listings
Review Code Reviewer Date
P1. Other Identifier: La Paz Village
*P2. Location: ☐ Not for Publication ☒ Unrestricted *a. County Orange and (P2c, P2e, and P2b or P2d. Attach a Location Map as necessary.) *b. USGS 7.5' Quad San Juan Capistrano, Calif. Date 2011 T 7S; R 8W; ¼ of ¼ of Sec 02; San Bernardino B.M. c. Address 25254, 25252, 25250, and 25758 La Paz Road City Laguna Hills Zip 92653 d. UTM: (Give more than one for large and/or linear resources) Zone 11, 436831 mE/ 3717532 mN e. Other Locational Data: (e.g., parcel #, directions to resource, elevation, decimal degrees, etc., as appropriate) APNs: 620-211- 17, 620-211-15, 620-211-18, 620-211-17, and 620-211-09
*P3a. Description: (Describe resource and its major elements. Include design, materials, condition, alterations, size, setting, and boundaries)
The API is located on the southern side of La Paz Road on four parcels in the La Paz Village commercial complex: 25254 La Paz Road (APN 620-211-17), 25250 La Paz Road (APN 620-211-18), 25252 La Paz Road (APN 620-211-15), and 25758 La Paz Road (APN 620-211-09). The API is relatively square in plan with five commercial buildings surrounded by asphalt parking lots.

Map ID 2 is located along the northeast corner of the API, with Map ID 1a along the southern boundary of the Area of Potential Impact (API), and Map IDs 1b, 3, and 4 are clustered together and set back from the northern boundary of the API. See Continuation Sheet page 4.
*P3b. Resource Attributes: (List attributes and codes) HP6. 1-3 Story Commercial Building *P4. Resources Present: ☒ Building ☐ Structure ☐ Object ☐ Site ☐ District ☐ Element of District ☐ Other (Isolates, etc.) P5b. Description of Photo: (View,
date, accession #) Photo 1, looking
southwest, July 26, 2024 (Dudek
IMG_1626.JPG)
*P6. Date Constructed/Age and
Sources:
 Historic  Prehistoric  Both
1974 /(Permit #92.942)
*P7. Owner and Address:

La Paz Village Investors LLC
1010 S. El Camino Real Ste 92682
San Clemente, CA 92672
*P8. Recorded by: (Name,
affiliation, address)
Katie Ahmanson, MHC
Dudek
225 S. Lake Ave, Ste. M210
Pasadena, CA 91101
*P9. Date Recorded: 9/6/2024
*P10. Survey Type: (Describe)
Intensive
P5a. Photograph or Drawing (Photograph required for buildings, structures, and objects.)

*Resource Name or # (Assigned by recorder) 25254, 25252, 25250, and 25758 La Paz Road DPR 523B *Required Information
State of California - The Resources Agency Primary #
DEPARTMENT OF PARKS AND RECREATION HRI#

BUILDING, STRUCTURE, AND OBJECT RECORD
B1. Historic Name: N/A
B2. Common Name: La Paz Village
B3. Original Use: Commercial
B4. Present Use: Commercial
*B5. Architectural Style: N/A
*B6. Construction History: (Construction date, alterations, and date of alterations) See Continuation Sheet page 5. *B7. Moved? ☒No ☐Yes ☐Unknown Date: Click here to enter a date. Original Location:
*B8. Related Features: associated parking lots
B9a. Architect: N/A b. Builder: Robert Kennedy
*B10. Significance: Theme N/A Area: N/A
Period of Significance N/A Property Type N/A Applicable Criteria N/A (Discuss importance in terms of historical or architectural context as defined by theme, period, and geographic scope. Also address integrity.)
25254, 25252, 25250, and 25758 La Paz Road do not meet the criteria for the National Register of Historic Places (NRHP), California Register of Historical Resources (CRHR). The property was evaluated in accordance with Section 106 of the National Historic Preservation Act (Section 106) and Section 15064.5 (a)(2)-(3) of the CEQA Guidelines using the criteria outlined in Section 5024.1 of the California Public Resources Code. The property is not considered a historic property for the purposes of Section 106 or a historical resource under CEQA. As such, this evaluation assigns a 6Z California Historical Resources Status Code to 25254, 25252, 25250, and 25758 La Paz Road. See Continuation Sheet page 6.

B11. Additional Resource Attributes: (List attributes and codes)
*B12. References: See Continuation Sheet page 10.

B13. Remarks:
*B14. Evaluator: Katie Ahmanson, MHC, Dudek
*Date of Evaluation: September 6, 2024
(This space reserved for official comments.)
(Sketch Map with north arrow required.)

*Map Name: San Juan Capistrano, Calif. *Scale: 1:24,000 *Date of map: 2011 DPR 523J * Required information
State of California - The Resources Agency Primary #
DEPARTMENT OF PARKS AND RECREATION HRI#
LOCATION MAP Trinomial

*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
*P3a. Description (continued from page 1)
Two concrete driveways provide access from La Paz Road and two concrete McIntyre Street. The API does not have any fences; landscaping includes sections of concrete planters with plantings and mature trees. Adjacent properties are developed with a one-story school to the south, one-story commercial buildings to the west and east, and one- and twostory residential buildings to the north and east.

Map ID 1a: 25254 La Paz Road (APN 620-211-17)
Map ID 1a was constructed in 1974. The commercial building is rectangular in plan and primarily one-story with a centralized two-story massing. The building features a flat roof with parapets atop the single-story wings, double-story massing with red-clay tile shed roofs with no overhang, and closed eaves supported by stone columns covering the pedestrian walkway along the north and east elevations of the building (Photograph 2).

The exterior walls are primarily clad with painted stucco with stone cladding along the base of the elevations.

Fenestration includes fully glazed, metal frame, single-leaf and double-leaf storefront doors and grouped, metal frame storefront windows. The building displays elements of the Spanish Colonial Revival architectural style, including simple rectangular massing, two-story height, a flat roof, red clay tile roofs with no overhang, and painted stucco cladding (Photograph 3).

Map ID 1b: 25254 La Paz Road (APN 620-211-17)
Map ID 1b was constructed in 1974. The commercial building is rectangular in plan and one story in height. It features a red-clay tile hipped roof with closed eaves and a flat roof section with a parapet (Photograph 4). The hipped roof primarily has no overhang; however, the roof has a wide overhang supported by stone clad columns along the primary (south) elevation that covers an outdoor courtyard enclosed with stone walls. The exterior walls are primarily clad with painted stucco with stone cladding along the base of the elevations. Fenestration includes fully glazed, metal frame, single-leaf and double-leaf storefront doors and grouped, metal frame storefront windows on the primary (south) and east elevations. The rear (north) elevation abuts the adjacent property, Map ID 4: 25758 La Paz Road (APN 620-211-09). The building displays elements of the Spanish Colonial Revival architectural style, including simple rectangular massing, one-story height, a red clay tile hipped roof with a flat roof section and minimal/no overhang, painted stucco cladding, and an outdoor courtyard (Photograph 5).

Map ID 2: 25250 La Paz Road (APN 620-211-18)
Map ID 2 was constructed in 1974. The commercial building is rectangular in plan and one story in height, with a flat roof featuring a parapet and red clay tile hipped roofs with no overhang, as well as closed eaves atop projecting rectangular volumes on all elevations (Photograph 6). The exterior walls are primarily clad with painted stucco and feature stone clad pilasters on all elevations. Additionally, the west and rear (north) elevations of the building feature a covered courtyard enclosed by a stone wall with stone columns supporting wood rafters (Photograph 7).

Fenestration includes fully glazed, metal frame, single-leaf and double-leaf storefront doors, and grouped, metal frame storefront windows. The building displays elements of the Spanish Colonial Revival architectural style, including simple rectangular massing, one-story height, a flat roof, red clay tile hipped roofs with no overhang, painted stucco cladding, and an outdoor courtyard.

Map ID 3: 25252 La Paz Road (APN 620-211-15)
Map ID 3 was constructed in 1974. The commercial building is rectangular in plan, one story in height, and features a flat roof with a parapet (Photograph 8). The exterior walls are primarily clad with painted stucco and include vertical wood board cladding on the primary (north), west, and east elevations. The primary (north) elevation is asymmetrical with a projecting rectangular massing, and a wood flat roof supported by wood posts extending from the elevation. The primary entry door is recessed and features a single leaf, fully glazed, metal frame storefront door. Fenestration on the primary (north), east, and west elevations include grouped, metal frame storefront windows with a metal frame casement drive-thru window located on the east elevation beneath the projecting hipped roof. Additionally, the rear (south) elevation features two attached ancillary sheds (Photograph 9).

*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
Map ID 4: 25758 La Paz Road (APN 620-211-09)
Map ID 4 was constructed in 1974. The commercial building is rectangular in plan and one story in height, with two massings each featuring a red-clay tile hipped roof with closed eaves and minimal overhangs, and a flat roof section with a parapet (Photograph 10). The exterior walls featuring a combination of cladding, including brick veneers along the primary (north) elevation and painted stucco cladding on the east, rear (south), and west elevations. Fenestration includes fully glazed, metal frame, single-leaf and double-leaf storefront doors, and grouped, metal frame storefront windows on the primary (north) and west elevations. The rear (south) elevation abuts the adjacent property, Map ID 3b:
25254 La Paz Road (APN 620-211-17). The building displays elements of the Spanish Colonial Revival architectural style, including simple rectangular massing, one-story height, a red clay tile hipped roof with a flat roof section and minimal overhang, and painted stucco cladding (Photograph 11). *B06. Construction History (continued from page 2)
Map ID 1a: 25254 La Paz Road (APN 620-211-17)
The following list of known building alterations to Map ID 1a was compiled through City of Laguna Hills building permits and during the course of the intensive survey:
• 1974: Establish a meat market and restaurant in basic building (Permit #264905) • 2012: Americans with Disabilities Act exterior renovations (Permit #1-12-5389) • Date unknown: Replacement of storefronts (observed)
Map ID 1b: 25254 La Paz Road (APN 620-211-17)
The City of Laguna Hills did not have any relevant building permits on file for Map ID 3b. The following list of known building alterations to Map ID 1b was compiled during the course of the intensive survey:
• Date unknown: Addition of awnings to primary (south) elevation (observed) • Date unknown: Replacement of storefronts (observed)
Map ID 2: 25250 La Paz Road (APN 620-211-18)
The following list of known building alterations to Map ID 2 was compiled through City of Laguna Hills building permits and during the course of the intensive survey:
• 1974: Construct restaurant building (Permit #96443)
• 2014: Tear down and rebuild 6,120 square feet (Permit #11-13-8234) • Date unknown: Addition of awnings (observed)
• Date unknown: Replacement of storefronts (observed)
Map ID 3: 25252 La Paz Road (APN 620-211-15)
The following list of known building alterations to Map ID 3 was compiled through City of Laguna Hills building permits and during the course of the intensive survey:
• 1974: Construct “drive-in restaurant” (Permit #92941
• 1993: Enclose existing outdoor seating (Permit #0833) • 2001: Reroof (Permit #12969)
• 2005: 1,104 square feet of new facade and the addition of a 260-square-foot patio (Permit #20005- 0372)
• 2015: Tear off flat roof and install four-play hot mop (Permit #9020) • 2024: New outdoor gathering space, upgraded building accessibility, a new entry portal, new exterior cladding, and new landscaping (Permit #0002-2024)
• Date unknown: Removal of hipped red clay tile roofs from tower volume and a drive-through window on the east elevation (observed)

*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
• Date unknown: Replacement of storefronts (observed)
Map ID 4: 25758 La Paz Road (APN 620-211-09)
The following list of known building alterations to Map ID 4 was compiled through City of Laguna Hills building permits and during the course of the intensive survey:
• 1992: Reroof (Permit # NR9202240009)
• Date unknown: Replacement of storefronts (observed)
*B10. Significance (continued from page 2):

This context is provided to ascertain what significant themes concern the history of the subject property. Dudek provides this context to better understand the context of any of the identified previously recorded or newly documented resources in the API. It begins with a general overview of the development of the Laguna Hills. The context then provides a discussion of the subject property’s development, including the history of owners and occupants, and the property typology (neighborhood shopping center).

Historical Overview of Laguna Hills
The City of Laguna Hills is located Orange County, California, and is named after its proximity to Laguna Canyon. Laguna Hills was developed on the former Rancho Niguel land in 1894. After Mexico won its independence from Spain in 1822, Alta California became part of the Mexican Republic, and the Mexican government opened California to foreign trade.

Private land grants were issued in the early 1820s, creating the rancho system of large agricultural estates. Rancho Niguel was granted to Juan Avila in 1842 and extended along the coast from Laguna Canyon to San Juan Creek, encompassing the present-day cities of Laguna Niguel, Aliso Viejo, and Laguna Hills. By 1848, America assumed formal control of the California with the Treaty of Guadalupe-Hidalgo and introduced Anglo culture and society. Avila continued to own the ranch until 1865, when he sold the property to John Forster. In 1895, Lewis Moulton and his partner Jean Pierre Daguerre purchased the property, and it became known as Moulton Ranch. Moulton and Daguerre used the property to raise cattle and sheep as well as to grow barley and beans (City of Laguna Hills 2024; City of Laguna Niguel 2024). The ranch became known as Moulton Ranch, and over time, Moulton increased the property from 19,000 acres to 26,000 acres. By 1908, Daguerre was granted one-third ownership of the ranch. Moulton and Daguerre continued to cultivate the land throughout the early 1900s as their ranch grew in success (City of Laguna Hills 2024).

The first half of the twentieth century saw little development as the area remained primarily agricultural. In 1938, Moulton passed away, so his wife, Nellie, went on to manage Moulton Ranch with Daguerre (City of Laguna Hills 2024).

Historic aerial photographs of the area during this period indicate that the land surrounding the ranch was primarily undeveloped rural landscape (NETR 2024a). The area comprising modern-day Laguna Hills remained undeveloped agrarian land until after World War II (1939–1945), when a massive wave of migration and corresponding building boom occurred throughout California. Development began in present-day Laguna Hills in the early 1950s, when Moulton Ranch was subdivided and sold to individual buyers who constructed single-family residences (City of Laguna Hills 2024). Historic newspaper research indicates that the Mission Viejo Company purchased 11,000 acres of the nearby Mission Viejo ranch in Mission Viejo to develop the first planned community in 1964; it also developed much of the surrounding areas of Mission Viejo and Aliso Viejo, as well as parts of Laguna Hills (CD 1964: 1; Moulton Museum 2024).

Increased residential construction also led to a rise in commercial properties and infrastructure to support the new population. By 1970, the Laguna Hills Plaza was constructed to serve the communities of Laguna Hills, El Toro, South Laguna, Laguna Niguel, Laguna Beach, Dana Point, Capistrano Beach, San Juan Capistrano, and San Clemente, followed by the Laguna Hills Mall in 1973 and the Wild West Plaza by 1974 (AB 1969: 31; CD 1972: 7; SPN 1976: 8).

While development increased, agriculture decreased, and Moulton Ranch was completely sold off in 1976, when the Mission Viejo Company purchased the ranch’s last lot. By then, the land comprising the former Moulton Ranch had become part of the present-day communities of Aliso Viejo, Laguna Hills, Laguna Niguel, and Laguna Woods. Residential and commercial growth of the Laguna Hills continued throughout the second half of the twentieth century, although the area remained partially developed until the late 1980s (City of Laguna Hills 2024; NETR 2024a).

*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
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DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
Efforts to incorporate the community of Laguna Hills began in 1987 with an approximate population of 45,000 residents (City of Laguna Hills 2024). By 1989, Laguna Hills was the fourth community proposed for incorporation in Orange County in 18 months, with two cities—Mission Viejo and Dana Point—incorporated in the year prior. However, voters in 1989 opposed the incorporation, with most of the opposition stating a fear of higher taxes (LAT 1989: 51). By 1991, 86% of the Laguna Hills residents voted in favor of incorporation, and Laguna Hills officially became a city on December 20, 1991. The community of North Laguna Hills was annexed and incorporated in 1996, and in 2000, the Westside community of Laguna Hills was annexed and incorporated, adding 149 acres of residential land to the city (City of Laguna Hills 2024). Presently, Laguna Hills includes a population of about 31,000 residents. The economy is primarily comprised of professional, scientific, and technical service industries (Data USA 2024).

Development of La Paz Village
The La Paz Village commercial complex (Map IDs 1–4) was constructed in 1974 on previously undeveloped land surrounded by a partially developed residential neighborhood (Exhibit 1). At the time of its construction, prior to the incorporation of Laguna Hills as an independent city in 1991, the shopping complex was called the Mission Hills Plaza, and it was constructed at a cost of $2 million. City building permits indicated that Robert L. Kennedy owned the properties at the time of their construction; Kennedy was also listed as the builder of the commercial buildings. There is no architect listed on the original building permits, and additional research did not identify the name of an architect associated with the development of the complex. Kennedy was the president of Mission Hills Realty Inc., a real estate development company active in Orange County during the 1970s. In addition to commercial properties, the company also developed and sold single-family residences and condominiums. It appears the company was relatively short lived, as Kennedy was convicted of income tax violations in 1980 (LAT 1974: 87; The Register 1976: 74; LAT 1980: 38).

Exhibit 1. 1972 aerial photograph (left) showing the API partially developed; 1980 aerial photograph (right) showing the extant API (outlined in red)
Source: NETR 2024a
Several businesses have occupied the buildings since their construction. Research identifies the following businesses located at unspecified addresses within the La Paz Commercial Complex in 1975: Mission Hills Hair Fashions; Laguna Hills Pharmacy and Natural Vitamin Center; The Better Mouse Trap, a gift store with pottery; and Cornell's, a camera store (Press-Telegram 1975: 89).

In 1981, the shopping complex was expanded with the construction of a commercial building at 25552 La Paz Road (APN 620-211-19), located to the west of Map IDs 1–4. There are no additional discernible changes to the footprints

*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
and spatial configuration of the La Paz Village commercial complex since its construction (NETR 2024a). The surrounding area was fully developed with residential and commercial development during the early 1980s. The La Paz Village commercial complex is presently owned by the La Paz Village Investors LLC (ParcelQuest 2024; City of Laguna Hills City Clerk 2024).

Typology of La Paz Village: Neighborhood Shopping Centers (1950-1990) After World War II, Americans, and particularly Southern Californians, became heavily reliant on automobile travel and were no longer restricted to shopping in downtown urban centers. New settlement patterns away from urban centers introduced new building types, including the neighborhood shopping center. Developers of this building type were able to dedicate more land for parking, which included clustering related stores around a generous amount of off-street parking. Typically, a neighborhood shopping center, which can be comprised of multiple buildings, was constructed at one time, which allowed for architectural continuity. In comparison to the earlier commercial blocks of independent shops, which varied in size, architectural style, and date of construction, neighborhood shopping centers had overall cohesion based on decisions made by the developer (Longstreth 1998, 2010; HRG 2007; Newman 1999).

Neighborhood shopping centers were developed to be smaller than regional shopping centers (with department stores) and larger than strip malls. They featured one medium-sized anchor store, such as a grocery store or discount retailer, surrounded by smaller retailers. The neighborhood shopping center was typically oriented to a front parking lot and arranged in a straight L- or U-shaped pattern. This type of layout originated in the 1950s and was popularized in the 1970s (Longstreth 1998, 2010; City of LA 2017; Newman 1999).

Characteristics of the neighborhood shopping center typology:
• Primary entrances of stores off the parking lot
• Large surface parking lots surrounding the building(s) • Disconnection from the street
• Designed to appear as a single unit with a unifying design • One to two stories in height
• Box-like massing
• Located outside urban centers
NRHP/CRHR Evaluation
Under NRHP Criterion A and CRHR Criterion 1, the buildings identified as Map IDs 1a, 1b, 2, 3, and 4 lack a direct and important association with any event significant in local, state, or national history. Map IDs 1–4 were constructed in 1974 as part of a shopping center originally called the Mission Hills Plaza (today, called La Paz Village). The subject properties share an association with the trends of commercial growth in Laguna Hills during the 1950s through the 1970s, but they did not contribute in any significant way to those trends. In Laguna Hills, the statewide factors causing population growth following World War II’s conclusion in 1945 were exacerbated by the subdivision of Moulton Ranch in the early 1950s, which brought many new residents to the area. By the late 1960s, the Mission Viejo Company developed much of the surrounding area; as a result, commercial development increased during this period, including shopping centers such as the subject property, the Laguna Hills Plaza (1970), the Laguna Hills Mall (1973), and the Wild West Plaza (1974). As a commercial property constructed in 1974, the subject property represents this trend of post-World War II commercial expansion. While this is an important trend both regionally and statewide, the subject property did not play a significant role in this trend, nor did it influence this trend. It was one of many commercial properties constructed in Laguan Hills during this period. According to archival research, there is no indication it is associated with events that have made a significant contribution to broad patterns of history. For these reasons, the subject properties do not appear eligible under NRHP Criterion A or CRHR Criterion 1.

Under NRHP Criterion B and CRHR Criterion 2, the buildings identified as Map IDs 1a, 1b, 2, 3, and 4 lack a direct and significant association with the productive life of any person considered important in history. Map IDs 1–4 were built by their original owner, Robert L. Kennedy. Kennedy was the president of Mission Hills Realty Inc. and developed commercial and residential properties in Orange County in during the 1970s before his company dissolved in 1980.

The subject properties have continued to function as a local shopping center with various business occupying the

*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
buildings since their construction. Presently, the La Paz Village commercial complex is owned by La Paz Village Investors LLC (ParcelQuest 2024). Research did not yield further information about Kennedy or the La Paz Village Investors LLC, and did not indicate that the subject properties have been associated with the life of a significant individual. Due to a lack of identified significant associations with important individuals, the subject properties do not appear eligible under NRHP Criterion B or CRHR Criterion 2.

Under NRHP Criterion C and CRHR Criterion 3, the buildings identified as Map ID 1a, 1b, 2, 3, and 4 lack design and construction value because they do not possess architectural distinction or high artistic value and do represent the work of a master or contribute to the significance of a district. The five commercial buildings all represent undifferentiated, largely unembellished, commercial buildings. The buildings are undistinguished examples of commercial architecture as applied to the neighborhood shopping center property type. The subject properties reflect several characteristics of the neighborhood shopping center typology, including primary entrances of stores off the parking lot, large surface parking lots surrounding the buildings, disconnection from the street, one story in height, and boxlike massing. However, the subject properties were significant examples of the property type in Laguna Hills or Orange County. Rather, the subject properties represent a common example of a 1970s commercial shopping center. Additionally, the buildings no longer represent a unifying design due to multiple alterations over the years that have inhibited their ability to reflect their historic design. These buildings reflect ubiquitous building trends from the period with rectangular plans, primarily painted stucco cladding, and parking lots surrounding the buildings. There are better and more intact examples of the 1970s neighborhood shopping centers throughout Laguna Hills, Orange County, and California. Original building permits for the subject properties indicate the original owner, Robert Kennedy, was listed as the builder of the properties.

Although Kennedy was the president of Mission Hills Inc., he does not appear to be a significant builder. As such, the buildings lack sufficient distinctive characteristics of a type, period, or method of construction; do not represent the work of a master; do not possess high artistic values; nor do they appear to be potential contributors to a historic district.

Therefore, the subject properties do not appear eligible under NRHP Criterion C or CRHR Criterion 3.

Under NRHP Criterion D and CRHR Criterion 4, the La Paz Village commercial complex is not significant as a source, or likely source, of important historical information, nor does it appear likely to yield important information about historic construction methods, materials, or technologies. This technology is well understood through contemporary trade journals and scientific monographs. As such, the subject property lacks significance under NRHP Criterion D and CRHR Criterion 4.

Integrity Considerations
Integrity is the ability of a property to convey its significance. Because the concept of integrity is based on significance, the assessment of a property’s integrity can only proceed after its significance has been fully established. The assessment of integrity requires consideration under the seven aspects or qualities. To retain integrity, a property will always possess several, and generally most, aspects of integrity. Determining which aspects are most important requires an understanding of why, where, and when the property is significant. Because the subject property evaluated in this report lack sufficient significance to meet any of the criteria for listing in the NRHP or CRHR, an integrity analysis was considered immaterial for the subject properties
Summary of Evaluation Findings
The subject properties were evaluated in consideration of NRHP and CRHR criteria and integrity requirements. As a result of the evaluation, Map ID 1a (25254 La Paz Road), Map ID 1b (25254 La Paz Road), Map ID 2 (25250 La Paz Road), Map ID 3 (25252 La Paz Road), and Map ID 4 (25758 La Paz Road) are recommended as ineligible for inclusion in the NRHP and CRHR. The recommended Status Code for Map IDs 1a, 1b, 2, 3, and 4 is 6Z. *B12. References (continued from page 2):

AB (Anaheim Bulletin). 1969. "Historic Swartz Farm Site to Become Shopping Center." June 14, 1969. Anaheim Bulletin (Newspapers.com: Anaheim, California). Page 31.

City of Laguna Hills. 2024. “History of Laguna Hills.” Laguna Hills, California: City of Laguna Hills. Accessed July 19, 2024. https://www.ci.laguna-hills.ca.us/247/History-of-Laguna-Hills.

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*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
City of Laguna Hills City Clerk. 2024. Building Permits. Laguna Hills, California: City of Laguna Hills. Received July 24, 2024.

City of Laguna Niguel. 2024. “History.” Laguna Niguel, California: City of Laguna Niguel. Accessed July 19, 2024. https://www.cityoflagunaniguel.org/388/History.

CD (Coastline Dispatch). 1964. "Mission Viejo Project Gets Okay of Planners." June 17, 1964. Coastline Dispatch (Newspapers.com: San Juan Capistrano, California). Page 1.

CD. 1972. "Four Major Department Stores Tagged For Laguna Hills Mall." May 31, 1972. Coastline Dispatch (Newspapers.com: San Juan Capistrano, California). Page 7.

Data USA. 2024. “Laguna Hills.” United States Census Bureau. Accessed July 22, 2024. https://datausa.io/ profile/geo/laguna-hills-ca/.

HRG (Historic Resources Group). 2007. Cultural Resources of the Recent Past Historic Context Report. Pasadena, California: City of Pasadena.

LAT (Los Angeles Times). 1974. "Shopping Centers." July 28, 1974. Los Angeles Times (Newspapers.com: Los Angeles, California). Page 87.

LAT. 1980. "Three Convicted on Income Tax Counts." June 27, 1980. Los Angeles Times (Newspapers.com: Los Angeles, California). Page 38.

LAT. 1989. “Laguna: Voters Reject Cityhood.” Newspapers.com: Los Angeles Times (Newspapers.com: Los Angeles, California). June 7, 1989. Page 51.

Longstreth, Richard. 1998. City Center to Regional Mall: Architecture, the Automobile, and Retailing in Los Angeles, 1920-1950. Cambridge, Massachusetts: The MIT Press.

Longstreth, Richard. 2010. The American Department Store Transformed, 1920-1960. New Haven, Connecticut: Yale University Press.

Moulton Museum. 2024. “Mission and History.” Laguna Hills, California: Moulton Museum. Accessed August 26, 2024. https://moultonmuseum.org/about-mission-and-history/.

NPS (National Park Service). 1995. National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. Washington, DC: Department of the Interior, Government Printing Office. https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf.

NETR (Nationwide Environmental Title Research LLC). 2024a. “Historic Aerial Photographs of La Paz Village, Laguna Hills, Orange County, CA, dating from 1938, 1946, 1952, 1967, 1972, 1980, 1981, 1985, 1987, 1988, 1992, 1993, 1994, 1995, 1996, 1997, 1998, 1999, 2000, 2002, 2003, 2004, 2005, 2009, 2010, 2012, 2014, 2016, 2018, and 2020” [map]. Accessed July 18, 2024. https://www.historicaerials.com/viewer.

NETR. 2024b. “Historic Topographic Maps of La Paz Village, Laguna Hills, Orange County, CA, dating from 1949, 1957, 1960, 1963, 1965, 1969, 1977, 1981, 2012, 2015, 2018, and 2022” [map]. Accessed July 18, 2024. https://www.historicaerials.com/viewer.

Newman, Morris. 1999. “In Rise and Fall of Malls, Weaker Ones Get Demalled.” Los Angeles Times (Los Angeles, California). December 14, 1999. https://www.latimes.com/archives/la-xpm-1999-dec-14-mn-43909- story.html.

ParcelQuest. 2024. “APNs: 620-211-15, 620-211-18, 620-211-17, and 620-211-09” [map]. ParcelQuest. Accessed July 22, 2024. https://pqweb.parcelquest.com/#home.

Press-Telegram. 1975. "Classified - Newcomers Welcome to the Wild West Plaza." August 31, 1975. Press-Telegram (Long Beach, California). Page 89.

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*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
SPN (Sun Post News). 1974. "Advertisements." July 3, 1974. Sun Post News (Newspapers.com: San Clemente, California). Page 8.

The Register. 1976. "Classified - Laguna Hills." August 22, 1976. The Register (Newspapers.com: Santa Ana, California).

*Pfa. Photographs (continued from page 1):

Photograph 2. Primary (north) elevation of Map ID 3a, view looking southwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_1627.JPG

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*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
Photograph 3. Primary (north) and west elevations of Map ID 3a, view looking southeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_1648.JPG
Photograph 4. Primary (south) and west elevations of Map ID 3b, view looking northeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_1608.JPG

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*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
Photograph 5. Primary (south) and east elevations of Map ID 3b, view looking northwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_1614.JPG
Photograph 6. Primary (south) and west elevations of 25250 La Paz Road, view looking northeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_6712

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*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
Photograph 7. East and rear (north) elevations of 25250 La Paz Road, view looking southeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_6722.JPG
Photograph 8. Primary (north) and east elevations of 25252 La Paz Road, view looking southwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_1568.JPG

Road
*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
Photograph 9. East and rear (south) elevations of 25252 La Paz Road, view looking northwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_6736.JPG
Photograph 10. Primary (north) and west elevations of Map ID 4, view looking southeast. Photograph taken on July 26, 2024.

Source: Dudek IMG_1584.JPG

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*Recorded by: Katie Ahmanson, MHC, Dudek *Date: February 5, 2024 ☒ Continuation ☐ Update DPR 523L * Required information
State of California - The Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
CONTINUATION SHEET Trinomial
Photograph 11. Primary (north) and east elevations of Map ID 4, view looking southwest. Photograph taken on July 26, 2024.

Source: Dudek IMG_1570.JPG

4912-8105-4057, v. 1

TRIBAL CONSULTATION SUMMARY

4921-7843-9273, v. 1
Tribal Consultation Summary
La Paz Village
Senior Housing Project
(Site Development Permit No. 0147-2023)
SEPTEMBER 2025
Prepared for:

CITY OF LAGUNA HILLS
24035 El Toro Road
Laguna Hills, California 92653
Contact: Jennifer Lowe, Community Development Director
Prepared by:
2721 Las Ramblas, Suite 340
Mission Viejo, California 92691
Contact: Rachel Struglia, PhD, AICP

4921-7843-9273, v. 1
Assembly Bill 52 Consultation
Assembly Bill (AB) 52 of 2014 amended California Public Resources Code (PRC) Section 5097.94 and added PRC Sections 21073, 21074, 21080.3.1, 21080.3.2, 21082.3, 21083.09, 21084.2, and 21084.3. AB 52 established that tribal cultural resources (TCRs) must be considered under the California Environmental Quality Act (CEQA), and also provided for additional Native American consultation requirements for the lead agency. PRC Section 21074 describes a TCR as a site, feature, place, cultural landscape, sacred place, or object that is considered of cultural value to a California Native American tribe. A TCR is defined as being the following:
▪ on the California Register of Historical Resources (CRHR) or a local historic register; ▪ eligible for the CRHR or a local historic register; or ▪ a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of California Public Resources Code Section 5024.1.

AB 52 requires the lead agency to initiate consultation with California Native American groups that are traditionally and culturally affiliated with a project site, including tribes that may not be federally recognized. Lead agencies are required to begin consultation prior to the release of a Negative Declaration, Mitigated Negative Declaration, or Environmental Impact Report by contacting those tribal groups that have previously provided a formal written request for notification of projects under the lead agency’s jurisdiction.

Section 1(a)(9) of AB 52 establishes that “a substantial adverse change to a tribal cultural resource has a significant effect on the environment.” Effects on TCRs should be considered under CEQA. Section 6 of AB 52 adds PRC Section 21080.3.2, which states that parties may propose mitigation measures “capable of avoiding or substantially lessening potential significant impacts to a tribal cultural resource or alternatives that would avoid significant impacts to a tribal cultural resource.” Further, if a California Native American tribe requests consultation regarding project alternatives, mitigation measures, or significant effects to TCRs, the consultation must include those topics (PRC Section 21080.3.2[a]). Finally, the environmental document on which the tribal consultation is focused and the Mitigation Monitoring and Reporting Program (where applicable) developed in consideration of information provided by tribes during the formal consultation process must include any mitigation measures that are adopted (PRC Section 21082.3[a]).

Before the recent passage of AB 130 (see below), the City of Laguna Hills (City) was in the process of assessing the La Paz Village Senior Housing Project (project) pursuant to CEQA. As such, the project was subject to compliance with AB 52 (PRC Section 21074), which requires consideration of impacts to TCRs as part of the CEQA process, and that the lead agency notify California Native American tribal representatives (that have requested notification) who are traditionally or culturally affiliated with the geographic area of the proposed project. All 23 California Native American tribal representatives identified on the Native American Heritage Commission’s contact list were sent letters from the City on January 23, 2025. The notification letters contained a project description, outline of AB 52 timing, an invitation to consult, a project site plan, and contact information for the appropriate lead agency representative. To date, three responses have been received by the City. Table 1 summarizes the results of the AB 52 process for the project.

4921-7843-9273, v. 1
Table 1. AB 52 NAHC–Listed Native American Contacts
Native American Tribal
Representatives Response Received
Chloe Soto, Gabrieleño Band of
Mission Indians – Kizh Nation
(Kizh Nation)
January 27, 2025
Email from Chloe Soto, on behalf of Kizh Nation, to the City acknowledging receipt of the AB 52 notification letter for the project and requesting consultation. Ms. Soto’s email also stated that the proposed project is within Kizh Nation’s Ancestral Tribal Territory.

February 10, 2025
Email from the City to Ms. Soto acknowledging receipt of Ms. Soto’s request for consultation on the project. The City additionally proposed AB 52 consultation by virtual meeting and at the discretion of Ms. Soto.

February 10, 2025
Follow-up email from Brandy Salas, on behalf of Kizh Nation, to the City scheduling a virtual consultation meeting for March 25 at 11:00 a.m.

March 24, 2025
Email from Ms. Salas to the City rescheduling the meeting on March 25. To avoid delays, Ms. Salas stated Kizh Nation would be happy to reschedule at a later date or proceed with consultation via email. The City suggested that the tribe send what information they can, then schedule a follow-up meeting if necessary.

March 25, 2025
Email from Ms. Salas to the City confirming agreement to this approach.

March 28, 2025
Email from the City to Ms. Salas providing the City’s proposed draft TCR mitigation measures for the tribe’s consideration and for inclusion in the IS/MND. The City requested the tribe provide any comments or suggestions and to let the City know if the mitigation measures were acceptable to the tribe.

April 3, 2025
Email from Kizh Nation to the City with a letter stating that the City’s proposed mitigation measures should be revised to only include mention of Kizh Nation in all project documents.

May 12, 2025
The City responded with a letter acknowledging the formal objection to the proposed mitigation measures. The City reiterated the requirement of AB 52 to consult with all tribes in a manner “which is meaningful...seeking, discussing, and considering carefully the view of others, in a manner that is cognizant of all parties’ cultural values.” The City referred to the State’s Tribal Consultation Guidelines acknowledging that “[o]ne or more tribes may have traditional cultural ties to the land within the local government’s jurisdiction and have an interest in preserving cultural places on those lands.” As a result, in compliance with state law, the City explained that the tribal consultation process must be inclusive of all tribes and the tribal cultural resources of all potentially impacted tribes. The diverse interests of the different tribes that claim cultural affiliation with the geographic area of the proposed project require the City to strike a delicate balance to protect the tribal cultural resources of all potentially impacted tribes. and the City could

4921-7843-9273, v. 1
Table 1. AB 52 NAHC–Listed Native American Contacts
Native American Tribal
Representatives Response Received
not agree to exclude other tribes from the tribal cultural resources mitigation measures. The City explained that it had acted in good faith and made reasonable efforts to reach a mutual agreement on the mitigation measures for the project and closed consultation.

May 12, 2025
Email correspondence from Ms. Salas asking to set up a time to discuss the mitigation measures.

May 21, 2025
The City responded to Ms. Salas and reiterated that consultation had been closed, and that unless the Kizh Nation had changed its position, there did not appear to be anything further to discuss.

Christina Conley, Gabrieleño
Tongva Indians of California
January 29, 2025
Email from Christina Conley, on behalf of the Gabrieleño Tongva Indians of California, to the City acknowledging receipt of the City’s AB 52 notification letter for the project and requesting the cultural reporting. Ms. Conley’s email also stated that the proposed project is in an area of concern to the Gabrieleño Tongva Indians of California.

February 10, 2025
Email from the City to Ms. Conley providing her with the SCCIC records search results for the project.

March 24, 2025
Email from the City to Ms. Conley following up on the project and inquiring as to whether any additional information was needed or if she had further questions.

March 26, 2025
Email from Ms. Conley to the City noting that the project site is sensitive for TCRs and that the tribe recommends Native American monitoring during ground disturbance for the project.

March 28, 2025
Email from the City to Ms. Conley providing the City’s proposed draft TCR mitigation measures for the tribe’s consideration and for inclusion in the IS/MND. The City requested that the tribe provide any comments or suggestions and to let the City know if the mitigation measures were acceptable to the tribe.

May 9, 2025
Ms. Conley emailed the City in response to the proposed draft TCR mitigation measures with an edit for inclusion in the IS/MND. The suggested edit would require the project applicant to retain a Native American monitor “from the interested tribe(s)” rather than a Native American monitor “from or approved by the interested tribe(s)”.

May 12, 2025
The City sent a letter concluding consultation. The City made the requested edit.

4921-7843-9273, v. 1
Table 1. AB 52 NAHC–Listed Native American Contacts
Native American Tribal
Representatives Response Received
Joyce Stanfield Perry, Juaneño
Band of Mission Indians,
Acjachemen Nation
February 10, 2025
Email from Joyce Perry, on behalf of the Juaneño Band of Mission Indians, Acjachemen Nation, to the City acknowledging receipt of AB 52 notification letter for the project and requesting consultation. Ms. Perry’s email stated that the proposed project is within the Juaneño Band of Mission Indians, Acjachemen Nation’s Ancestral Tribal Territory and requested the City provide her with additional project information, SCCIC records search results, and proposed mitigation measures prepared for the project.

Ms. Perry additionally stated that due to the sensitivity of the project site, her preliminary recommendation is that mitigation measures include Native American monitoring.

February 24, 2025
Email from the City to Ms. Perry acknowledging receipt of Ms. Perry’s request for consultation on the project.

February 27, 2025
Email from the City to Ms. Perry providing her with the SCCIC records search results for the project.

March 13, 2025
Email from Ms. Perry to the City requesting the site record for P-30-000426 and confirming the tribe’s recommendation for Native American monitoring.

In this correspondence, Ms. Perry also provided the tribe’s proposed TCR mitigation measures for the project.

March 28, 2025
Email from the City to Ms. Perry providing the City’s proposed draft TCR mitigation measures for the tribe’s consideration and for inclusion in the IS/MND. The City requested that the tribe provide any comments or suggestions and to let the City know if the mitigation measures were acceptable to the tribe.

March 28, 2025
Email from Ms. Perry to the City approving the City’s draft TCR mitigation measures prepared for the project.

April 18, 2025
The City sent a letter concluding consultation.

BobbyRay Esparza, Cahuilla
Band of Indians
No response from tribe.

Erica Schenk, Cahuilla Band of
Indians
No response from tribe.

Anthony Madrigal, Cahuilla
Band of Indians
No response from tribe.

Christina Swindall Martinez,
Gabrieleno Band of Mission
Indians – Kizh Nation
No response from tribe.

4921-7843-9273, v. 1
Table 1. AB 52 NAHC–Listed Native American Contacts
Native American Tribal
Representatives Response Received
Andrew Salas, Gabrieleno Band
of Mission Indians – Kizh
Nation
No response from tribe.

Anthony Morales,
Gabrieleno/Tongva San Gabriel
Band of Mission Indians
No response from tribe.

Robert Dorame, Gabrieleno
Tongva Indians of California
Council
No response from tribe.

Sandonne Goad,
Gabrieleno/Tongva Nation
No response from tribe.

Charles Alvarez, Gabrieleno
Tongva Tribe
No response from tribe.

Sonia Johnston, Juaneno Band
of Mission Indians
No response from tribe.

Heidi Lucero, Juaneno Band of
Mission Indians Acjachemen
Nation
No response from tribe.

Norma Contreras, La Jolla
Band of Luiseno Indians
No response from tribe.

Shasta Gaughen, Pala Band of
Mission Indians
No response from tribe.

Christopher Nejo, Pala Band of
Mission Indians
No response from tribe.

Alexis Wallick, Pala Band of
Mission Indians
No response from tribe.

Temet Aguilar, Pauma Band of
Luiseno Indians
No response from tribe.

Steven Estrada, Santa Rosa
Band of Cahuilla Indians
No response from tribe.

Vanessa Minott, Santa Rosa
Band of Cahuilla Indians
No response from tribe.

Joseph Ontiveros, Soboba
Band of Luiseno Indians
No response from tribe.

Jessica Valdez, Soboba Band
of Luiseno Indians
No response from tribe.

Notes: AB = Assembly Bill; NAHC = Native American Heritage Commission; City = City of Laguna Hills; TCR = tribal cultural resource; IS = Initial Study; MND = Mitigated Negative Declaration; project = La Paz Village Senior Housing Project; SCCIC = South Central Coastal Information Center.

4921-7843-9273, v. 1
AB 130 Tribal Consultation
On June 30, 2025, AB 130 was signed into law. On July 15, 2025, the applicant for the project notified the City of its position that the project is exempt from review under CEQA pursuant to AB 130 (PRC Section 21080.66). AB 130 includes its own set of provisions regarding consultation with Native American tribes. The new AB 130 provisions appeared to change the sequence regarding, but not the substance of, tribal consultation.

The prior tribal consultation for this project was conducted and completed under AB 52 (PRC Section 21080.3.1).

To ensure that the tribes that had participated in the AB 52 consultation process were provided the level of consultation to which they are legally entitled, the City notified the tribes on August 4, 2025, that the project applicant had invoked AB 130 and inquired whether any tribe had a desire for any further consultation. Due to the timing constraints of AB 130, the City requested responses by August 15, 2025. On August 4, 2025, Hereditary Chief Andrew Salas of the Gabrieleño Band of Mission Indians – Kizh Nation responded that the Kizh Nation had not changed its position since the AB 52 consultation on this project. On August 7, 2025, Ms. Joyce Stanfield Perry, Juaneño Band of Mission Indians, Acjachemen Nation, responded that she had no further concerns and asked to be contacted prior to the commencement of work on the project. No further response was received from the Gabrieleño Tongva Indians of California either before August 15, 2025, as requested, or as of the publication date of this document.

Attachment 5
Link to Project Documents:
https://www.lagunahillsca.gov/537/La-Paz-Village-Builders-Remedy-Project-D

Item No. 7.1.1
City of Laguna Hills
City Council / Planning Agency
Staff Report
Date: September 23, 2025
To: Mayor and Council Members
From: Joe Ames, Interim City Manager
Greg Simonian, City Attorney
Jennifer Lee, City Clerk
Issue: Resolution of Intent to Transition from At-Large to By-District Elections and Approval of a Proposed Consulting Services Agreement with National Demographics, Inc.

Recommendation: That the City Council:

1. Adopt a Resolution entitled: "A Resolution of the City Council of the City of Laguna Hills, California, Declaring Its Intention to Transition from At-Large to ByDistrict Elections Pursuant to California Elections Code Section 10010 and Finding the Proposed Transition Exempt from the California Environmental Quality Act Pursuant to State CEQA Guidelines Sections 15061(b)(3), 15320, and 15378(b)(5)"; and

2. Approve a proposed Consulting Services Agreement with National Demographics, Inc., (NDC) for the provision of expert elections, demographic and districting consulting services, and authorize the Interim City Manager to execute the proposed agreement with NDC.

Background:

Since incorporating in 1991, registered voters in the City of Laguna Hills (“City”) have elected their City Council Members using an “at-large” system in which city council members are elected by all registered voters to provide city-wide representation. In 2002, the State Legislature enacted the California Voting Rights Act (“CVRA”), modifying

Item No. 7.1.1
burden of proof requirements contained in the federal Voting Rights Act of 1965 to make it much easier for plaintiffs to challenge the at-large system of elections for cities.

The CVRA prohibits a public agency from using at-large elections if it impairs the ability of a protected class, as defined, to elect candidates of its choice or otherwise influence the outcome of an election. The CVRA includes the imposition of district-based elections by a court as a remedy to violations of the Act, and requires the public agency to pay all legal and court fees should the plaintiff prevail in court.

In a letter received by the City Clerk on June 20, 2023, attached hereto, Michelle R.

Jackson, an attorney representing an undisclosed registered voter and resident of the City of Laguna Hills, alleged that the City’s at-large elections system violates the CVRA because it results in “racially polarized voting” that dilutes the impact of Latino voters.

The 2023 letter demanded that the City voluntarily change its at-large system for electing City Council members to a district-based system to avoid litigation. The initial demand letter failed to identify the name of the Prospective Plaintiff and contained no direct evidence of any racially polarized voting prepared by a qualified demographer.

Despite repeated requests, attorney Michelle Jackson refused to identify the name of the Prospective Plaintiff.

On August 28, 2025, the City Clerk received a follow-up letter from attorney Michelle R.

Jackson, dated August 25, 2025, also attached hereto, wherein Ms. Jackson referenced her initial June 20, 2023 letter and renewed her demand that the City voluntarily change from the current at-large election system to by-district elections. In her August 25, 2025 renewed demand letter, attorney Michelle Jackson identified for the first time the Prospective Plaintiff as being the “Voter Equality Association” and “Arthur Sanchez,” a registered voter in the City, and provided the City with some additional information regarding her assertion that the City’s at-large election system violates the California Voting Rights Act; however, once again failing to provide any direct evidence of racially polarized voting prepared by a qualified demographer. In her August 25, 2025 renewed demand letter, Ms. Jackson once again demands that the City voluntary change to by-district elections.

In her August 25, 2025 renewed demand letter, Ms. Jackson has now imposed a new deadline date of October 15, 2025 for the City to decide to voluntarily change to bydistrict elections, which deadline is more than 45-days from the date of her renewed demand, in order to avoid litigation. In doing so, she gives the City one last opportunity to voluntarily change to by-districts elections in order to avoid litigation – i.e., giving the City another 45-day period in which to consider the matter. In her most recent demand letter, she once again threatens litigation should the City fail to voluntarily change to by-district elections.

Item No. 7.1.1
While Ms. Jackson’s demand letters do not include any direct evidence of racially polarized voting to support her claim that the CVRA has been violated by the City’s use of an at-large election system, it is in the public interest to begin the process of transitioning from at-large to district-based elections and to complete that process within 90-days due to the uncertainty of litigation to defend against a CVRA lawsuit and the potentially extraordinary cost to defend such a lawsuit, even if the City were to prevail in court.

The vast majority of cities receiving a similar letter demanding a change of their at-large elections to district-based elections have avoided protracted litigation by voluntarily transitioning from at-large to district-based elections citing the extraordinary cost of legal defense and potential liability for significant attorney fees and settlement costs if the city’s legal defense of its at-large election system is unsuccessful in court.

Now that attorney Michelle Jackson has identified the name of the Prospective Plaintiff in her most recent August 25, 2025 letter, and in order to avoid costly litigation, the City wishes to voluntarily change to district-based elections pursuant to Elections Code Section 10010 and wishes to immediately commence the process by adopting a resolution outlining its intention to transition from at-large to district-based elections, specifying steps it will undertake to facilitate this transition, and including an estimated timeframe for doing so.

Discussion:

The California Voting Rights Act
The CVRA, codified as Elections Code sections 14025 et seq., became law on January 1, 2003. The CVRA was specifically enacted to eliminate several key burden of proof requirements that exist under the federal Voting Rights Act of 1965 (52 USC § 10301 et seq.) after several jurisdictions in California successfully defended themselves in litigation brought under the federal Voting Rights Act. The CVRA made fundamental changes to minority voting rights in California, making it much easier for plaintiffs in California to challenge the at-large voting systems of any political subdivision on the basis that they result in dilution of voting power for minority groups. Any voter who resides in a city and is a member of a protected class may file a lawsuit for a violation of the CVRA. To succeed, the plaintiff must only show that, as a result of an at-large election, “racially polarized voting” has occurred.

Item No. 7.1.1
Under State law violations of the CVRA may be established by a showing that “racially polarized voting” has occurred in an at-large election and presumes that such showing impairs the ability of a protected class to elect candidates of its choice or to influence the outcome of an election; a “protected class” means a class of voters who are members of a race, color, or language minority group, as this class is referenced and defined in the federal Voting Rights Act of 1965 (52 U.S.C. Sec. 10301 et seq.); and “racially polarized voting” means voting in which there is a difference, as defined in case law regarding enforcement of the federal Voting Rights Act of 1965 (52 U.S.C. Sec. 10301 et seq.), in the choice of candidates or other electoral choices that are preferred by voters in a protected class, and in the choice of candidates and electoral choices that are preferred by voters in the rest of the electorate. The methodologies for estimating group voting behavior as approved in applicable federal cases to enforce the federal Voting Rights Act of 1965 (52 U.S.C. Sec. 10301 et seq.) to establish racially polarized voting may be used for purposes of enforcing the CVRA in order to prove that elections are characterized by racially polarized voting.

If the plaintiff prevails in litigation, the CVRA guarantees an award of attorney fees to the successful plaintiff; the CVRA allows for the recovery of substantial attorney fees and expert witness fees. A city can reasonably expect the possibility of a court awarding the plaintiff a seven-figure attorney fee award if it chooses to fight a CVRA lawsuit and is unsuccessful. On the other hand, if the city prevails in the lawsuit, it cannot recover either its attorney fees or costs. Consequently, cities throughout the State of California have increasingly faced legal challenges to their at-large election systems. Because of the low burden of proof, and the low probability of litigation success, nearly all have settled claims out of court by voluntarily transitioning to district-based elections. We know of no public agency that has been able to successfully defend a CVRA lawsuit.

Such litigation is labor-intensive, time-consuming, and expert driven, so adverse judgments are costly and settlements are typically $200,000 - $800,000, or more, in addition to the city’s attorney fees and costs.

The Procedure to Transition to District-Based Elections Government Code Section 34886 authorizes a city council to adopt an ordinance to change its method of election from an at-large system to a district-based system, in which each council member is elected only by the voters in the district in which the candidate resides; and Elections Code Sections 10010 authorizes a city council to adopt a resolution of intention to change its method of elections and to transition from an atlarge system to a by-districts system, and Section 10010 provides the process for initiating a transition to district-based elections.

Item No. 7.1.1
To transition to a district-based system, the City Council must adopt an ordinance requiring City Council members to be elected by district or by district with an elected mayor, pursuant to Government Code Section 34886 and Elections Code Section 10010.

Pursuant to Government Code Section 34886, the ordinance does not need to be submitted to the voters for approval, but must include a declaration that the change in election procedures is being made to further the purposes of the CVRA.

To do so, the City Council must first adopt a resolution of intent to consider an enactment to change to a district-based election system beginning for use in the November 2026 General Municipal Election for the election of members of the City Council. In the resolution of intent, the City Council must outline its intention to consider transitioning from at-large to district-based elections, set forth the specific steps it will undertake to facilitate this proposed transition, and provide a tentative estimated timeframe for doing so. The proposed resolution of intent is attached hereto.

The City must then take the following actions in accordance with Elections Code Section 10010(a), taking into consideration the time required for meaningful public outreach and input, and the statutory timeframes established by the Elections Code:

1. Conduct public outreach, including to non-English speaking communities, to explain the process for considering the transition from at-large to district-based elections and to facilitate public participation;

2. Before drawing a draft map or maps of the proposed boundaries of the districts, the City Council must hold at least two (2) public hearings over a period of no more than 30 days at which members of the public will be invited to provide input regarding the composition of the districts, pursuant to Elections Code Section 10010;

3. After drawing a draft map or maps, the City Council must publish the draft map or maps and the potential sequencing of elections necessary in order to transition to district-based elections, and the City Council must hold at least two (2) additional public hearings over a period of no more than 45 days at which members of the public will be invited to provide input regarding the proposed district boundaries and the proposed sequence of the district elections;

4. Hold a public hearing for the City Council to consider and adopt an ordinance establishing district-based elections, including the adoption of a districting map and the sequence of the district elections.

At the conclusion of the foregoing public hearings, the Council will then be asked to hold a public hearing to consider adoption of an ordinance establishing district-based elections.

Item No. 7.1.1
The creation and approval of voting district maps is intended to be a transparent, interactive public process. Voting district maps must be prepared in compliance with certain State and Federal requirements; therefore, the use of qualified expert demographer is required. Of import is Elections Code Section 10010(b), which provides that, in determining the sequence of the district elections, the city council shall give special consideration to the purposes of the CVRA and it shall take into consideration the preferences expressed by members of the districts. The districting process must also include consideration of the following criteria when drawing district maps: 1) geographically contiguous; 2) undivided neighborhoods and “communities of interest”; 3) easily identifiable boundaries/ natural geographic boundaries; 4) compactness; and 5) all voting districts be as nearly equal in population as possible. Finally, federal caselaw prohibits drawing districts with race as a predominate factor.

Additionally, since 2023 there have been several changes in CVRA law, which impact the specific process and procedures used by public agencies to change from at-large to by-district elections. The changes in law, effective January 1, 2024, also require the preparation of certain reports, as well as compliance with other requirements, and the districting body cannot adopt election district boundaries for the purpose of favoring or discriminating against an incumbent, political candidate, or political party.

Conclusion:

If the City Council does not adopt the proposed Resolution of Intent on or before the October 15, 2025 deadline imposed by attorney Michelle Jackson, the City will most likely be required to defend a CVRA lawsuit, incur significant legal costs, and assume the potential liability for the Prospective Plaintiffs’ attorney fees and costs that could reach into the millions of dollars. To date, there is no established CVRA case law in which a defendant city has successfully prevailed on the merits. The cost to defend and/or settle CVRA lawsuits has proven to be significant, with examples including:

Palmdale: $4.7 million Santa Barbara: $600,000
Modesto: $3 million Palm Desert: $555,000
Santa Clara: $4.55 million Tulare Hospital: $500,000
Highland: $1.3 million Santa Clarita: $370,000
Anaheim: $1.1 million Camarillo: $233,000
Whittier: $1 million Cypress: $835,000
We are unaware of any city that has ultimately prevailed in a lawsuit defending an atlarge election system under the CVRA. The City of Santa Monica lost in a CVRA case at the trial court level, but later prevailed in the appellate court; however, the California

Item No. 7.1.1
Supreme Court subsequently granted review. The Santa Monica CVRA lawsuit went up on appeal to the California Supreme Court. Some CVRA experts believe that Santa Monica had spent more than $10 million prior to appealing to the California Supreme Court, and the plaintiffs had requested $22 million in attorney, expert fees, and litigation costs in connection with their win in the trial court. The California Supreme Court ultimately remanded the case back down to the lower court for further proceedings where the case remains. Some CVRA experts estimate that, in all likelihood, it will cost Santa Monica somewhere in the range of $15-20 million defending its at-large voting system.

Finally, it is important to note that in addition to requiring the payment of plaintiff’s attorney fees and expert witness fees, the court’s remedial powers under the CVRA are extremely broad, and specifically include the power to implement appropriate remedies, including court ordered imposition of by-district elections. In other words, a court could ultimately order the City to implement by-district elections, and the court could potentially decide the composition of the districts without any say by the public or the City Council.

Completion of the process to switch to by-district elections requires the services of a qualified expert. Therefore, approval of a proposed Consulting Services Agreement with National Demographics, Inc., (NDC) for the provision of expert elections, demographic and districting consulting services is recommended.

Fiscal Impact:

Expert costs associated with the City retaining a qualified demographer are expected to be approximately $45,000 - $75,000. There will also be additional costs to engage the City Attorney’s office, consultants, and public engagement efforts.

Attachments:

1. Proposed Resolution of Intent to Transition from At-Large to By-District Elections

2. Demand Letter from Attorney Michelle R. Jackson, Dated June 20, 2023

3. Renewed Demand Letter from Attorney Michelle R. Jackson, Dated August 25, 2025

4. Proposed Consulting Services Agreement with National Demographics

4917-0860-5800, v. 1
RESOLUTION NO. 2025-09-23-X

A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF

LAGUNA HILLS, CALIFORNIA, DECLARING ITS
INTENTION TO TRANSITION FROM AT-LARGE TO BYDISTRICT ELECTIONS PURSUANT TO CALIFORNIA ELECTIONS CODE SECTION 10010 AND FINDING THE

PROPOSED TRANSITION EXEMPT FROM THE

CALIFORNIA ENVIRONMENTAL QUALITY ACT

PURSUANT TO STATE CEQA GUIDELINES SECTIONS
15061(b)(3), 15320, AND 15378(b)(5)
The City Council of the City of Laguna Hills, California, hereby finds, determines, declares, and resolves as follows:

WHEREAS, Members of the City Council of the City of Laguna Hills (“City”) are currently elected by the at-large method of election rather than the by-district election system; the at-large method of election is one in which the voters of the entire jurisdiction elect the members to the governing body; the by-district method of election is a method of electing members to the governing body of a political subdivision in which the candidate must reside within an election district that is a divisible part of the political subdivision and is elected only by the voters residing within that election district; and WHEREAS, Government Code Section 34886 authorizes a city council to adopt an ordinance to change its method of election from an at-large system to a districtbased system, in which each council member is elected only by the voters in the district in which the candidate resides; and
WHEREAS, Elections Code Sections 10010 authorizes a city council to adopt a resolution of intention to change its method of elections and to transition from an at-large system to a by-districts system, and Section 10010 provides the process for initiating a transition to district-based elections; and WHEREAS, on June 20, 2023, the City Clerk received a letter from Michelle R. Jackson of the Law Offices of Michelle R. Jackson, an attorney representing an undisclosed registered voter and resident of the City of Laguna Hills (“Prospective Plaintiff”) asserting that the City’s at-large election system violates the California Voting Rights Act (“CVRA”) and threatening litigation if the City declines to voluntarily change to a district-based election system for electing council members; and WHEREAS, on August 28, 2025, the City Clerk received a follow-up letter from attorney Michelle R. Jackson, dated August 25, 2025, wherein Ms. Jackson referenced her June 20, 2023 letter and renewed her demand that the City voluntarily change from the current at-large election system to by-district elections; in her August 25, 2025 renewed demand letter she identified for the first time the Prospective Plaintiff as being the “Voter Equality Association” and “Arthur Sanchez,” a registered voter in the City, and provided the City with additional information regarding her assertion that the City’s at-large election system violates the California Voting Rights Act; however, once again

Resolution No. 2025-09-23-X

4917-0860-5800, v. 1
failing to provide any direct evidence of racially polarized voting prepared by a qualified demographic expert; and
WHEREAS, in her August 25, 2025 renewed demand letter, Ms. Jackson once again requests that the City voluntary change to by-district elections and that it make the decision to do so prior to the imposed October 15, 2025 deadline in order to avoid litigation; and
WHEREAS, while Ms. Jackson’s letters do not include any direct evidence of racially polarized voting to support her claim that the CVRA has been violated by the City’s use of an at-large election system, it is in the public interest to begin the process of transitioning from at-large to district-based elections and to complete that process within 90-days due to the uncertainty of litigation to defend against a CVRA lawsuit and the potentially extraordinary cost to defend such a lawsuit, even if the City were to prevail in court; and
WHEREAS, under State law violations of the CVRA may be established by a showing that “racially polarized voting” has occurred in an at-large election and presumes that such showing impairs the ability of a protected class to elect candidates of its choice or to influence the outcome of an election; a “protected class” means a class of voters who are members of a race, color, or language minority group, as this class is referenced and defined in the federal Voting Rights Act of 1965 (52 U.S.C. Sec. 10301 et seq.); and
WHEREAS, “racially polarized voting” means voting in which there is a difference, as defined in case law regarding enforcement of the federal Voting Rights Act of 1965 (52 U.S.C. Sec. 10301 et seq.), in the choice of candidates or other electoral choices that are preferred by voters in a protected class, and in the choice of candidates and electoral choices that are preferred by voters in the rest of the electorate. The methodologies for estimating group voting behavior as approved in applicable federal cases to enforce the federal Voting Rights Act of 1965 (52 U.S.C. Sec. 10301 et seq.) to establish racially polarized voting may be used for purposes of enforcing the CVRA in order to prove that elections are characterized by racially polarized voting; and WHEREAS, now that the Prospective Plaintiff has been properly identified by attorney Michelle Jackson in her August 25, 2025 renewed demand letter, and in order to avoid costly litigation, the City wishes to voluntarily change to district-based elections pursuant to Elections Code Section 10010 and wishes to commence the process by adopting a resolution outlining its intention to transition from at-large to district-based elections, specifying steps it will undertake to facilitate this transition, and including an estimated timeframe for doing so; and
WHEREAS, adoption of a district-based system of elections will not affect the current terms of office for any currently seated City Council Members; and WHEREAS, the City Council has determined that under the circumstances presented, and based on the current state of the law, it would be in the City’s best interest at this time to immediately commence the process for transitioning from at-large to districtPage 1928 of 1981 Resolution No. 2025-09-23-X

4917-0860-5800, v. 1
based elections pursuant to Elections Code Section 10010; and WHEREAS, the City Council desires to adopt this Resolution for the purpose of a) outlining its intention to transition from at-large to district-based elections, b) specifying the steps it will undertake to facilitate this proposed transition, and c) providing an estimated timeframe for doing so, pursuant to Elections Code Section 10010 and Government Code Section 34886

NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF LAGUNA

HILLS, CALIFORNIA, DOES RESOLVE, DECLARE, DETERMINE, AND ORDER AS FOLLOWS:

SECTION 1. Recitals. The foregoing recitals are true and correct and are hereby incorporated by reference herein.

SECTION 2. Intention to Transition to a District-Based Election System for Electing Members of the City Council. Pursuant to Elections Code Section 10010 and Government Code Section 34886, the City Council hereby declares its intent at this time to consider an enactment to change to a district-based election system beginning for use in the November 2026 General Municipal Election for the election of members of the City Council.

SECTION 3. Specification of Steps for Transition Plan. The City Council hereby outlines its intention to consider transitioning from at-large to district-based elections, sets forth the specific steps it will undertake to facilitate this proposed transition, and provides an estimated timeframe for doing so. Following the effective date of this Resolution, the City intends to take the following actions in accordance with Elections Code Section 10010(a), taking into consideration the time required for meaningful public outreach and participation, and the statutory timeframes established by the Elections Code:
a) Conduct public outreach, including to non-English speaking communities, to explain the process for considering the transition from at-large to district-based elections and to facilitate public participation;
b) Before drawing a draft map or maps of the proposed boundaries of the districts, the City Council will hold at least two (2) public hearings over a period of no more than 30 days at which members of the public will be invited to provide input regarding the composition of the districts, pursuant to Elections Code Section 10010;
c) After drawing a draft map or maps, the City will publish the draft map or maps and the potential sequencing of elections necessary in order to transition to district-based elections, and the City Council will hold at least two (2) additional public hearings over a period of no more than 45 days at which members of the public will be invited to provide input regarding the proposed district boundaries and the proposed sequence of the district elections;

Resolution No. 2025-09-23-X

4917-0860-5800, v. 1
d) Hold a public hearing for the City Council to consider and adopt an ordinance establishing district-based elections, including the adoption of a districting map and the sequence of the district elections.

SECTION 4. Use of Demographer Services. City Council and City staff will work with a qualified expert demographer to provide an analysis of the City’s current demographics and any other information or data necessary to prepare a draft map(s) that appropriately divides the City into voting districts in a manner consistent with the intent and purpose of the CVRA and the Federal Voting Rights Act.

SECTION 5. Estimated Timeframe. The City Council hereby approves the estimated 90-day timeline as set forth in Exhibit “A”, attached hereto and made a part of this Resolution, for conducting a public outreach process to solicit public input on proposed district-based electoral maps before adopting any such map. The estimated timelines contained in Exhibit “A” may be adjusted by the Interim City Manager / City Manager as deemed necessary, given the upcoming holiday season, provided that such scheduling adjustments shall not prevent the City from complying with the timeframes specified by Elections Code Section 10010, and shall not prevent the City from switching to a district-based election system beginning for use in the November 2026 General Municipal Election for the election of members of the City Council.

SECTION 6. CEQA. Based on the whole of the administrative record before it, the City Council hereby finds that transitioning from at-large to district-based elections is exempt from environmental review under the California Environmental Quality Act (“CEQA”) (Public Resources Code Section 21000 et seq.) pursuant to State CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.) sections 15061(b)(3), 15320, and 15378(b)(3).) In the event adoption of this Resolution does constitute a project for purposes of CEQA, it is hereby determined to be categorically exempt under the Class 20 (Changes in the Organization of Local Governments) categorical exemption. (State CEQA Guidelines Section 15320.) SECTION 7. Notice of Exemption. The City Clerk is hereby directed to prepare and file with the Orange County Clerk-Recorder a CEQA Notice of Exemption within five (5) business days of the adoption of this Resolution.

SECTION 8. Severability. If any section, subsection, subdivision, sentence, clause, phrase, or portion of this Resolution is, for any reason, held to be invalid or unconstitutional by the decision of any court of competent jurisdiction, such decision shall not affect the validity of the remaining portions of this Resolution. The City Council hereby declares that it would have adopted this Resolution and each section, subsection, subdivision, sentence, clause, phrase, or portion thereof, irrespective of the fact that any one or more section, subsection, subdivision, sentence, clause, phrase, or portion thereof be declared invalid or unconstitutional.

SECTION 9. Certification. The City Clerk shall attest and certify to the passage and adoption of this Resolution.

Resolution No. 2025-09-23-X

4917-0860-5800, v. 1
SECTION 10. Effective Date. This Resolution shall take effective immediately upon adoption.

PASSED, APPROVED AND ADOPTED this 23rd day of September 2025. ____________________________________

JOSHUA SWEENEY, MAYOR
ATTEST:
______________________________________

JENNIFER LEE, CITY CLERK

STATE OF CALIFORNIA )
COUNTY OF ORANGE ) ss

CITY OF LAGUNA HILLS )
I, Jennifer Lee, City Clerk of the City of Laguna Hills, California, DO HEREBY CERTIFY that the foregoing is a true and correct copy of Resolution No. 2025-09-23-X adopted by the City Council of the City of Laguna Hills, California, at a Regular Meeting thereof held on the 23rd day of September 2025, by the following vote:

AYES:

NOES:

ABSENT:

ABSTAIN:
(SEAL)
_____________________________________

JENNIFER LEE, CITY CLERK

Resolution No. 2025-09-23-X

4917-0860-5800, v. 1
Exhibit “A”
ESTIMATED TIMELINE: CONSIDERATION AND IMPLEMENTATION OF

A PROPOSED DISTRICT-BASED ELECTION METHOD

DATE EVENT COMMENT
September 23, 2025
City Council adopts Resolution
declaring its intention to
transition from at-large to
district-based elections
Resolution of Intent to Transition
September –
November, 2025
Public Outreach regarding
process and to encourage public
participation
October 7, 2025
(Proposed Special
Meeting)
1st Public Hearing
City Council 1st hearing
regarding composition of
districts; no maps yet.

October 14, 2025
(Regular Meeting)
2nd Public Hearing
Must be conducted no more
than 30 days from the 1st public
hearing date-noticed and heard
at fixed time1.*
City Council 2nd hearing
regarding composition of
districts; no maps yet.

No Later Than
October 21, 2025
Post draft maps and potential
sequence of elections.

Draft maps and proposed
sequence of elections must be
posted publicly at least 7 days
before 3rd Public Hearing.

October 28, 2025
(Regular Meeting)
3rd Public Hearing
Noticed and heard at fixed time*.

City Council 3rd hearing
regarding composition of
districts.

No Later Than
November 11, 2025
Post any new or amended maps
and potential sequence of
elections.

Draft maps and proposed
sequence must be posted
publicly at least 7 days before 4th
Public Hearing.

November 18, 2025
(Adjourned Regular
Meeting)
4th Public Hearing – Select
map, City Council introduces
ordinance establishing district
elections, including district
boundaries and election
sequence. First Reading of
ordinance. Noticed/fixed time*
City Council 4th hearing; map
selected; ordinance introduced.

Must be conducted no more
than 45 days from the 3rd public
hearing date.

December 9, 2025
(Regular Meeting)
5th Public Hearing – adoption of
ordinance establishing district
elections – noticed and heard at
fixed time*.

City Council 5th hearing;
adoption of ordinance.
[End of process.]
Day 90 – December 22, 2025
1 *Elect. Code 10010(a)(3) provides, “(3) If a public hearing held pursuant to this section is consolidated with a regular or special meeting of the governing body of the political subdivision that includes other substantive agenda items, the public hearing shall begin at a fixed time regardless of its order on the agenda, except that the governing body of the political subdivision may first conclude any item being discussed or acted upon, including any associated public comment, when that time occurs. The governing body shall provide notice of the public hearing to the public.”

CHY OF LAGUNA HILLS RC
Jl!N 20 2023 PM2:55 Eato Offices of Jlll.ichelle R. Jackson 34189 PCH, Suite 204
Dana Point, CA 92629
(949)606-2674

VIA HAND DELIVERY
June 20, 2023
Attn: Jennifer Lee
City Clerk
City of Laguna Hills
Laguna Hills City Hall
24035 El Toro Road
Laguna Hills, CA 92653
Re: Violations of the California Voting Rights
Dear Ms. Lee,
I write on behalf of my client, a registered voter and resident in the City of Laguna Hills ("Laguna Hills"), who is concerned about minority residents voting in Laguna Hills.

Laguna Hills relies upon an at-large election system for electing candidates to its City Council.

Moreover, a review of Laguna Hills' voting results appears to illustrate that they are racially polarized, resulting in minority vote dilution. Therefore, Laguna Hills' at-large elections violate the California Voting Rights Act of 2001 ("CVRA").

The CVRA disfavors the use of "at-large" voting since this method effectively prevents a protected class from having a sufficient opportunity to elect a candidate of choice. See generally Sanchez v Modesto (2006) 145 Cal App4th 660,667. Further, these at-large election systems often result in the dilution or impairment of minority voters and their ability to elect candidates more representative of their neighborhoods by allowing a bare majority of voters to control every seat, not just a proportional majority of seats. See Thornburg v Gingles (1986) 478 U.S. 30, 46.

To find a violation, the CVRA only requires that there be a showing of racially polarized voting.

See Cal. Blee. Code § 14028 ("A violation of Section 14027 is established if it is shown that racially polarized voting occurs ... "). It is my client's position that Laguna Hills' system of at-large elections dilutes the ability of Latinos, a protected class, to elect candidates of their choice or otherwise influence the outcome of Laguna Hills' elections for its City Council Members.

During the last twenty (20) years, not a single Latino has been elected to the Laguna Hills City Council. This is concerning given that Latinos currently comprise the second largest race and ethnicity population in Laguna Hills with more than 20% of the City's population identifying as 1

Latino. This lack of Latino participation in seeking election to the city council is prima facia evidence of voter dilution on the part of the City. See generally Westwego Citizens for Better Government v City of Westwego 872 F2d 1201 (5
th Cir. 1989). There is a clear disconnect
between the significant Latino population in Laguna Hills and the complete absence of Latinos on the City Council further evidencing the inherent discrimination of the elections process in Laguna Hills.

In accordance with the above, it is respectfully requested that Laguna Hills change the manner in which it elects councilmembers to its city council and adopt a district system. Please be advised that ifwe do not have some movement with regard to this issue by August 4, 2023, we will be forced to seek judicial relief on behalf of residents within the jurisdiction.

CC: City Council
City Manager
2

VIA CERTIFIED MAIL
August 25, 2025
Attn: Jennifer Lee
City Clerk
City of Laguna Hills
Laguna Hills City Hall
24035 El Toro Road
Laguna Hills, CA 92653
Re: Violations of the California Voting Rights
Dear Ms. Lee,
~~ ()~ °"~
34145 PCH,
?<.

Suite
~
334
Dana Point, CA 92629
(949)606-2674
I write on behalf of my clients, Voter Equality Association and several minority voters residing in the City of Laguna Hills, including Arthur Sanchez, to follow up on my previous letter of June 20, 2023. The City of Laguna Hills ("Laguna Hills" or "City") continues to rely upon on at-large election system for electing candidates to its governing body. Moreover, voting within the City is racially polarized, resulting in minority vote dilution, and therefore Laguna Hills' at-large elections violate the California Voting Rights Act of 2001 ("CVRA").

The CVRA disfavors the use of "at-large" voting - an election method that permits voters of an entire jurisdiction to elect candidates to each open seat. See generally Sanchez v. City of Modesto (2006) 145 Cal.App.4th 660,667 ( "Sanchez"). For example, if the California State Assembly were elected through a state-wide at-large election, rather than through typical single member districts, each voter could cast up to 80 votes and vote for any state assembly candidate in the state, not just the candidates in that voter's district, and the 80 candidates receiving the most statewide votes would be elected. The problem with this system is that it enables a simple majority group (e.g., 51% of voters) to potentially control 100% of the seats, even if the other 49% are geographically or demographically concentrated and would otherwise win some representation. At-large elections thus allow a bare majority of voters to control every seat, not just the seats in a particular district.

Voting rights advocates have targeted "at-large" election schemes for decades because they often result in "vote dilution," or the impairment of minority groups' ability to elect their preferred candidates or influence the outcome of elections, which occurs when the electorate votes in a racially polarized manner.

See Thornburg v. Gingles, 478 U.S. 30, 46 (1986) ( "Gingles"). The U.S. Supreme Court "has long recognized that multi-member districts and at-large voting schemes may operate to minimize or cancel out the voting strength" of minorities. Id. at 4 7. "[T]he majority, by virtue of its numerical superiority, will regularly defeat the choices of minority voters." Id. When racially polarized voting occurs, dividing the political unit into single-member districts, or some other appropriate remedy, may facilitate a minority group's ability to elect its preferred representatives. See Rogers v. Lodge, 458 U.S. 616.

Section 2 of the Federal Voting Rights Act ("FVRA"), 42 U.S.C.§ 1973, which was enacted in 1965 and amended in 1982, targets among other things, at-large election schemes. Gingles at 37. Although the FVRA was successful in many states, California was an exception. Hoping to expand the protections against vote dilution over those provided in the FVRA in California, the legislature enacted the CVRA.

Thus, while the CVRA is similar to the FVRA in several respects, it is also different in several key respects, as the Legislature sought to remedy what it considered "restrictive interpretations given to the federal act." Assem. Com. On Judiciary, Analysis of Sen. Bill No. 976 (2001-2002 Reg. Sess.) as amended Apr. 9, 2002, p. 2.

In the CVRA, the California Legislature intentionally dispensed with the requirement in Gingles. See Sanchez, at 660, 669 wherein the court held that the CVRA removes the geographic compactness requirement of Gingles thereby lowering the burden on plaintiffs alleging racially polarized voting.

Recently, in Pico Neighborhood Association v. City of Santa Monica (August 24 2023) 15 Cal. 5th 292, the California Supreme Court reaffirmed this reading of the CVRA, holding that: "The CVRA does not require plaintiffs to show that a protected class can constitute a majority in a hypothetical single-member district."
Hence to establish a violation of the CVRA, a plaintiff must generally show that "racially polarized voting occurs in elections for members of the governing body of the political subdivision or in elections incorporating other electoral choices by the voters of the political subdivision." Elec. Code § 14028(a). The CVRA specifies that the elections that are most probative are, elections in which at least one candidate is a member of a protected class or elections involving ballot measures, or other electoral choices that affect the rights and privileges of members of a protected class." Elec. Code§ 14028(a). The CVRA also makes clear that "[ e ]lections conducted prior to the filing of an action ... are more probative to establish the existence of racially polarized voting that elections conducted after the filing of the action." Id.

Factors other than, "racially polarized voting" that are required to make out a claim under the FVRA - under the "totality of the circumstances" test - "are probative, but not necessary factors to establish a violation" of the CVRA. Elec. Code § 14028( e ). These "other factors" include "the history of discrimination, the use of electoral devices or other voting practices or procedures that may enhance the dilutive effects of at-large elections, denial of access to those processes determining which groups of candidates will receive financial or other support in a given election, the extent to such as education, employment, and health, which hinder their ability to participate effectively in the political process, and the use of overt or subtle racial appeals in political campaigns." Id.

According to the U.S. Census, Laguna Hills has a population of 30,378, with Latinos comprising approximately 22% of the City's population. Despite having a 22% Latino population, there has never been a Latino councilmember, nor has there been a Latino serving on Laguna Hills' most powerful commission, the planning commission. In fact, in the past 20 years there has been only one (1) Latino appointed to any commission within the City of Laguna Hills, this appointment was made in 2020. This information highlights a significant disparity between the demographic makeup of Laguna Hills and the representation of Latinos in its local government and commissions. Additionally, this underrepresentation could raise concerns about equitable access to civic engagement and representation in decision-making.

Laguna Hills at-large system dilutes the ability of Latinos (a "protected class") - even with that significant proportion of the City's electorate - to elect candidates of their choice or otherwise influence the outcome of elections. In the area north of Alicia Parkway in Laguna Hills, there is an area, which could be a district in a by-district voting system, that consists of approximately 63% minority voting population (49% Latino and 14% Asian). This potential district could result in a sufficient vote to elect a Latino or other minority councilmember. White voters represent approximately 34% in this same proposed district.

Using this proposed district, north of Alicia Parkway, as an example, in the 2022 State Senate race between Alex Padilla (a Latino) and Mark Mueser, Padilla received a majority of votes in this proposed district, whereas Mueser prevailed in the city-wide count. The 2022 race between Padilla and Mueser shows that a by-district system could allow a Latino to be elected. 2

Given the historical lack of representation of Latinos on the Laguna Hills City Council or in positions of leadership within the City, we urge the City to voluntarily change its at-large system of electing governing board members. Otherwise, on behalf ofresidents within the Laguna Hills jurisdiction, we will be forced to seek judicial relief. Please advise us no later than October l 5, 2025 as to whether you would like to discuss a voluntary change to your current at-large system.

I look forward to hearing from you soon.
3

Item No. 9.1
City of Laguna Hills
City Council / Planning Agency
Staff Report
Date: September 23, 2025
To: Mayor and Council Members
From: Kayle McDonald, Deputy City Clerk
Issue: Committee Assignment Report
Recommendation: That the City Council receive reports from City Council Members on the City Council Committee Assignments listed in the staff report.

Background:

The following are recent meetings and events attended by the City Council for their City Council Committee Assignments.

Transportation Corridor Agencies (TCA)
Board of Directors
Council Member Pezold
September 11, Joint Board Meeting
Orange County Older Adults Advisory Commission (OCOAAC) Council Member Wheeler
September 12, Regular Meeting
Orange County Mosquito and Vector Control (OCMVCD)
Board of Trustees
Council Member Pezold
September 18, Regular Meeting

Item No. 9.1
Fiscal Impact:

The City does not provide any additional compensation to City Council Members for serving on outside agency board or committees.

Attachments:

None