A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 40 Figure 28. South elevation, facing north.
Figure 29. Photograph showing the north and east elevations, facing southwest.
A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 41
LANDSCAPE
The landscape consists of shrubs and trees, including pine and oak trees (Figure 30 and Figure 31).
Approximately 75% of the front yard is covered in hardscape, including pavers and a concrete and brick driveway, and concrete block planter beds. There is wooden fencing along the north, west, and east perimeter of the Property, and wood and metal privacy fencing in the backyard along the southwest corner of the ca. 1933 detached garage.
Figure 30. Frontyard, facing northeast.
A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 42 Figure 31. Backyard, facing northeast.
EVALUATION OF HISTORICAL SIGNIFICANCE
The Property, including the 1929 house, ca. 1933 detached garage, and landscape was evaluated to determine individual eligibility for listing on the CRHR. The 1929 house was evaluated for its association with Colonial Revival architecture with a period of significance of 1929, the year the house was constructed. The ca. 1933 detached garage, and landscape are not associated with any style architectural landscape design or landscape planning.
CALIFORNIA REGISTER OF HISTORICAL RESOURCES
The CRHR is an inventory of significant architectural, archaeological, and historical resources in California.
Resources can be listed in the CRHR through several methods. State Historical Landmarks and NRHP listed properties are automatically listed in the CRHR. Properties can also be nominated to the CRHR by local governments, private organizations, or citizens. The CRHR follows similar guidelines to those used for the NRHP.
98 One difference is that the CRHR identifies the Criteria for Evaluation numerically instead of alphabetically. Another difference, according to the OHP is that “It is possible that historical resources may not retain sufficient integrity to meet the criteria for listing in the NRHP, but they may still be eligible for listing in the California Register. A resource that has lost its historical character or appearance may still have sufficient integrity for the California Register if it maintains the potential to yield significant scientific or historical information or specific data”.
99 98 California Code of Regulations, Title 14, Chapter 11.5, Section 4850 et seq. 99 California Office of Historic Preservation Technical Assistance Series #6 California Register and National Register: A Comparison (for purposes of determining eligibility for the California Register).
A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 43 A property must possess significance under one of the four criteria and have historic integrity to qualify for listing in the CRHR. Determining integrity consists of evaluating seven variables or aspects that include location, design, setting, materials, workmanship, feeling, and association. According to the National Register Bulletin: How to Apply the National Register Criteria for Evaluation, these seven characteristics are defined as follows:
• Location is the place where the historic property was constructed. • Design is the combination of elements that create the form, plans, space, structure, and style of the property.
• Setting addresses the physical environment of the historic property inclusive of the landscape and spatial relationships of the building(s).
• Materials refer to the physical elements that were combined or deposited during a particular period of time and in a particular pattern of configuration to form the historic property. • Workmanship is the physical evidence of the crafts of a particular culture or people during any given period in history.
• Feeling is the property’s expression of the aesthetic or historic sense of a particular period of time. • Association is the direct link between an important historical event or person and a historic property.
The following section examines the CRHR eligibility of the Property containing the 1929 house, ca. 1933 detached garage, and landscape.
CRHR EVALUATION
1. (Event): Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage.
The Property, including the 1929 house, ca. 1933 detached garage, and landscape, was not found to be associated with any event that made a significant contribution to California’s history and cultural heritage.
Therefore, the Property, including the 1929 house, ca. 1933 detached garage, and landscape, is not individually eligible for listing in the CRHR under Criterion 1.
2. (Person): Is associated with the lives of persons important in our past.
A thorough literature search and review of the Property owners and occupants was completed; however, the research did not reveal any person associated with the Property that is important to our past who is eligible for listing on the CRHR.
Therefore, the Property does not appear individually eligible for listing in the CRHR under Criterion 2.
3. (Construction/Architecture): 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.
A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 44 Architecture: The 1929 house is associated with Colonial Revival architecture, with a period of significance of 1929. The 1929 house consists of elements of the Colonial Revival design, including the side-gabled one-and-one-half-story form, wood clapboard siding, divided light wood windows, and symmetrical primary façade. Although the building is constructed in the Colonial Revival style, it does not embody the distinctive characteristics of Colonial Revival architecture and is not representative of the design. In addition, it does not embody a method of construction and does not represent the work of an important creative individual or possess high artistic values.
The ca. 1933 detached garage, and landscape are not associated with any style architectural landscape design or landscape planning.
Therefore, the 1929 house, ca. 1933 detached garage, and landscape within the Property do not appear to be individually eligible for listing in the CRHR under Criterion 3.
4. (Information potential): Has yielded, or may be likely to yield, information important in prehistory or history.
Criterion 4 most commonly applies to resources that contain or are likely to contain information on an important archaeological research question. While most often applied to archaeological sites, Criterion 4 can also apply to built environment resources that contain important information. For a building to be eligible under Criterion 4, it must be a principal source of important information, such as exhibiting a local variation on a standard design or construction technique can be eligible if a study can yield important information, such as how local availability of materials or construction expertise affected the evolution of local building development.
The 1929 house does not appear to be able to convey important information about Colonial Revival architecture. As such, the 1929 house, ca. 1933 detached garage, and landscape within the Property are not eligible for listing in the CRHR under Criterion 4. The Property was not assessed for archaeology.
LOCAL ASSESSMENT AND RECOMMENDATION
Because local inventories, including the 2011 documentation of the 1929 house, often do not meet the documentation and evaluation requirements needed to assess impacts to historical resources under CEQA,100 it is important to ensure that the documentation and evaluation of a historic property is complete following OHP and CEQA guidelines.101 Although the 1929 house is currently a locally listed historical resource, the City has requested an “updated” local assessment of all the built environment within the Property following the current Los Altos Municipal Code Section 12.44.040 to advise the city on continued local listing of the 1929 house, or listing of the ca. 1933 or landscape within the Property. Please note that the integrity analysis is 100 Office of Historic Preservation, “Historic Resource Surveys,” (accessed 4/18/2025), https://ohp.parks.ca.gov/?page_id=23317.
101 The OHP suggests that although “an existing survey over five years old can provide valuable information, it is appropriate to update the survey to ensure that local planning and preservation decisions are based on the most current information available.”
A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 45 part of the city’s ordinance; and though similar in wording is different than what is required as part of the NPS and OHP guidelines that require a building, structure, site, object, or district to first have significance prior to completing an integrity analysis.
ASSESSMENT
12.44.040 - Criteria for Designation.
A structure, property or object may be eligible for designation as a historic (sic)102 resource or historic landmark, if it/they satisfy each of the three criteria listed below:
A. Age. A structure or property should be more than fifty (50) years in age.103 (Exceptions can be made to this rule if the building(s) or site(s) is/are truly remarkable for some reason - such as being associated with an outstanding architect, personage, usage or event).
EDS Assessment: The Property, including the 1929 house and ca. 1933 detached garage, is over 50 years old. As such, the Property including the 1929 house and ca. 1933 detached garage retain integrity of Age.
B. Determination of Integrity.104 A structure (sic)105 or property should retain sufficient historic integrity in most of the following areas:
1) Design: The combination of elements that create the form, plan, space, structure and style of a property.
EDS Assessment: The original side-gable form of the house from 1929 remains intact, and modest elements of Colonial Revival design are present including the wood clapboard siding, divided light wood windows, and symmetrical primary façade. However, having these design elements alone is not enough to consider a building to be representative of Colonial Revival architecture. The 1929 house lacks distinctive features including a prominent front entrance, including columns or pilasters, is a paired down version of the style, and lacks quality of design throughout to represent this style. As such, EDS recommends that the 1929 house lacks the integrity to convey significance for its association with Colonial Revival architecture.
The ca. 1933 detached garage is not associated with any architectural style or form. 2) Setting: The physical environment of a historic property.
EDS Assessment: The setting has changed since the construction of the 1929 house, but the setting remains a small neighborhood with modest-sized houses set back from the street and designed in 102 Historical resource.
103 Just for reference, the NPS guidelines is at least 50 years old, and not more than 50 years in age. 104 Integrity is an assessment tool devised by the NPS and utilized by the OHP to assess a historical resources ability to convey significance. An integrity analysis is only completed if a building, structure, object, site, or district is found to be significant. Although EDS did not find any of the buildings within the Property significant, the 1929 house is currently locally listed. As such, EDS utilized the City’s “integrity” analysis to assess integrity for continued local listing. 105 See the definition on page 5 detailing the OHP guidelines (take from the NPS) for the five classes of cultural resources.
A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 46 various styles.
As such, the Property including the 1929 house and ca. 1933 detached garage retain integrity of setting.
3) Materials: The physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property.
EDS Assessment: The 1929 house retains the original wood clapboard siding on three of the four elevations; ten divided light wood windows; two paired, divided light windows; and wood shutters on the primary façade appear to be original from 1929. Although the intent of ‘integrity of material’ is to support or not support significance findings – in this case EDS did not find the 1929 house to be eligible under any significance criterion, the 1929 house does retain materiality from 1929.
EDS Assessment: The ca. 1933 garage has been significantly modified in materials; however, the exterior cladding and several windows may be original. As such, it retains a reduced amount of integrity of materials from ca. 1933.
4) Workmanship: The physical evidence of the crafts of a particular culture or people during any given period in history or prehistory.
Workmanship is “the evidence of artisans' labor and skill in constructing or altering a building, structure, object, or site. Workmanship can apply to the property as a whole or to its individual components. It can be expressed in vernacular methods of construction and plain finishes or in highly sophisticated configurations and ornamental detailing. It can be based on common traditions or innovative period techniques. Workmanship is important because it can furnish evidence of the technology of a craft, illustrate the aesthetic principles of a historic or prehistoric period, and reveal individual, local, regional, or national applications of both technological practices and aesthetic principles. Examples of workmanship in historic buildings include tooling, carving, painting, graining, turning, and joinery.”106
EDS Assessment: The workmanship evident on the 1929 house is very modest, as the house is a simple variation of the Colonial Revival style adapted to meet the lot size and the owner’s budget.
Though the wood windows with lugs show workmanship, these windows were not produced onsite, instead these windows were in mass production by this time, and most were purchased via millwork companies or lumber yards. In addition, the clapboard, shutters, and dentil were also likely purchased at a lumberyard or mill (unknown if the work is local or from nearby companies, which produced these standardized window and frame units). Furthermore, the workmanship evident on the house does not show any special skill in Colonial Revival design, as it does not include the Classical detailing (sometimes exaggerated), including pediments, columns or pilasters leading to elaborate entries, which is where workmanship is often showcased through handtooling, carving, painting, or joinery. Therefore, the integrity of workmanship in association with 106 National Park Service, “How to Apply the National Register Criteria for Evaluation,” 1990 (Revised 1995).
A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 47 Colonial Revival design is not present. In addition, although there is some degree of skill required to construct a house, this is not the intent of the term “workmanship” to mean basic construction techniques, which are present within the 1929 house—though modest at best. As such, EDS recommends that the 1929 house does not meet the requirement for integrity of materials. 5) Feeling: A property's expression of the aesthetic or historic sense of a particular period of time.
EDS Assessment: Physical features, taken together, convey a property's historic character.
However, 1929 is a modest example of Colonial Revival Architecture, which was popular in the U.S. from 1880 to ca. 1955. This house was not intended to meet the grander expectations of a Colonial Revival house—instead, the owner likely chose elements that they liked for the modest house. As such, the building fails to evoke the architectural details and spirit of the style. As such, EDS recommends that the 1929 house does not meet the requirement for integrity of feelings.
Although the significance finding should come before an integrity analysis for the following section, EDS completed this documentation in accordance with 12.44.040 and the order as laid out within the ordinance. This section was completed as an update to determine continued eligibility for local listing.
C. Historic Significance. A structure or property should be clearly associated with one or more of the following areas of significance:107
1) Event: Associated with a single significant event or a pattern of events that have made a significant contribution to broad patterns of local or regional history, or cultural heritage of California or the United States;108
EDS Assessment: None of the current built environment resources within the Property are not currently listed on the NRHP, the CRHR, or locally for association with an event. The EDS HRE determined that the Property is not eligible for listing on the CRHR for association with any event.
In addition, the Property was not found to be associated with any event that have made a significant contribution to broad patterns of local or regional history, or cultural heritage of California or the U.S. for local listing. As such, the Property, including the 1929 house, ca. 1933 detached garage, and landscape are not eligible for local listing under this criterion. 2) Person/People: Associated with the lives of persons important to the local, California or national history;
EDS Assessment: A thorough literature search and review of the Property owners and occupants was completed; however, the research did not reveal any person associated with the Property that is important to our past who is eligible for local listing under this criterion. 3) Architecture/Design: Embodies the distinctive characteristics of a design-type, period, region or method of construction, or represents the work of a master or possesses high artistic value; or 107 https://ohp.parks.ca.gov/?page_id=21238
108 NRHP Criterion: Is associated with events that have made a significant contribution to the broad patterns of our history (Criterion A); .
A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 48 EDS Assessment: The 1929 house is associated with Colonial Revival architecture, with a period of significance of 1929. The 1929 house consists of modest elements of the Colonial Revival design, including the side-gable form, wood clapboard siding, divided light wood windows, and symmetrical primary façade. Although the building is constructed in the Colonial Revival style, it does not embody the distinctive characteristics of Colonial Revival architecture and is not representative of the design. In addition, it does not embody a method of construction and does not represent the work of a master or possess high artistic values. Therefore, the 1929 house does not appear eligible for continued listing on the local HRI.
The ca. 1933 detached garage, and landscape are not associated with any style architectural landscape design or landscape planning.
4) Archaeology: Yields important information about prehistory or history of the local area, California or the nation.
EDS Assessment: The Property was not assessed for archaeology.
RECOMMENDATIONS
Based on the findings in the HRE and local assessment, EDS recommends that the 1929 house within the Property is removed from the City of Los Altos HRI as it does not appear to meet the criteria of Section
12.44.040 due to loss of integrity and/or historic significance. In addition, the ca. 1933 detached garage and landscape are not eligible for local listing under any significance criterion.
CONCLUSION
In accordance with CEQA regulations and guidelines, EDS completed an HRE of the 0.23-acre property at 81 Pepper Drive, Los Altos, Santa Clara County, California including the 1929 house, ca. 1933 detached garage, and landscape. The HRE was completed to determine if any of the built environment resources within the Property are eligible for listing on the CRHR. The HRE was completed by EDS Principal Architectural Historian Stacey De Shazo, M.A., and Architectural Historian Nicole Wyton, M.S., who exceed the Secretary of the Interior’s qualification standards in Architectural History and History, and Researcher Bee Thao, M.A. The HRE determined that the Property containing the 1929 house, ca. 1933 detached garage, and landscape does not appear individually eligible for listing on the CRHR under any criteria. However, the 1929 house is listed on the local Los Altos HRI.109 As such, the 1929 house is considered a Historical Resource as defined in Section 15064.5 of the CEQA Guidelines. However, based on the updated local assessment, EDS recommends that it be removed (delisted) from the HRI. If removed, the 1929 house would not be a historical resource under CEQA.
109 The 1929 house was not assigned a “California Register Historic Status Code.”
A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 49
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A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. 53 Appendix A:
DPR Forms
P1. Other Identifier: ____
DPR 523A (9/2013) *Required information
State of California The Resources Agency Primary #
DEPARTMENT OF PARKS AND RECREATION HRI #
PRIMARY RECORD Trinomial
NRHP Status Code
Other Listings
Review Code Reviewer Date
*P2. Location: Not for Publication Unrestricted
*a. County Santa Clara County and
*b. USGS 7.5' Quad Mountain View Date 1991 T 6S ; R 2W ; of of Sec un ; MD B.M. c. Address 81 Pepper Drive City Los Altos Zip 94022
d. UTM: Zone 10N , 578583 mE/ 4137124 mN
e. Other Locational Data: The resource is within the 0.23-acre Assessor Parcel Number (APN) 107-41-007. The Property is located on the north side of Pepper Drive, approximately 474 feet east of San Antonio Road. *P3a. Description: The resource includes the 1929 house, ca. 1933 detached garage, and landscape. The 1929 house is associated with Colonial Revival architecture. The 1929 house is associated with Colonial Revival architecture. The building is a side-gabled, one-and-one-half-story form that rests on a board-formed concrete and post and pier foundation. The house consists of a steep-pitched roof clad in asphalt shingles. (Continued on Continuation Sheet, Page 2) *P3b. Resource Attributes: HP2.
Single family property (1929 house);
HP4. Ancillary building (ca. 1933
detached garage )
*P4.Resources Present: Building Structure Object Site District Element of District Other
P5b. Description of Photo: 1929
house, facing north
*P6. Date Constructed/Age and
Source:Historic Prehistoric
Both 1929 house and ca. 1933
detached garage; various sources
*P7. Owner and Address: Withheld
by owners
*P8. Recorded by: Stacey De Shazo,
M.A., Evans & De Shazo, Inc. 1141
Gravenstein Highway S, Sebastopol,
California 95472
*P9. Date Recorded: 1/13/2025
*P10. Survey Type: Intensive
*P11. Report Citation: Stacey De Shazo and Nicole Wyton, with Bee Thao (2025): A Historic Resource Evaluation of the Property at 81 Pepper Drive, Los Altos, Santa Clara County, California. *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 Other (List):
P5a.
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
(Continued from Primary, page 1)
1929 House
The 1929 house is associated with Colonial Revival architecture (Figure 1). The building is a side-gabled oneand-one-half-story form that rests on a board-formed concrete and post-and-pier foundation. The house consists of a steep-pitched roof clad in asphalt shingles. A chimney is located along the roof ridge, and it is clad in stucco. The building is clad in wood clapboard on three elevations, with the rear elevation (north elevation) consisting of no cladding due to a permit in process.
Figure 1. South elevation, facing north.
South Elevation (Primary Facade)
The south elevation is the primary façade is symmetrical (Figure 2). At the first story, there is a centered, wooden front door flanked by side lights, each with four lights with simple mutins and a lower wood panel.
The door is a replacement wood-paneled door with two window lights. The front door is accessed via a paved driveway, with the entrance threshold resting at the ground level. Although the primary façade is on a raised foundation, it is not visible as the clapboard has been extended to the ground. There is a modern, arched arbor in front of the door, which serves as a “covered porch,” which is not original to the house. The front door is flanked by two pairs of six-over-one, divided light, wood windows with lugs (Figure 3). There are decorative wood shutters that flank the windows. The roof consists of three original, front-gable dormers with six-over-six, divided light, wood windows with lugs. The windows are trimmed in wood casing, with a slightly projecting windowsill. The dormers are clad in wood clapboard and the dormer roofs are clad in asphalt shingles (Figure 4). Below the eave of the roof there is a simple dentil that runs the length of the
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
primary façade.
Figure 2. Primary façade, facing north.
Figure 3. Photograph showing a pair of windows along the primary façade.
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
Figure 4. Photograph showing the three roof dormers.
West Elevation
The west elevation consists of five windows (Figure 5). There are two, six-over-one, divided light, wood windows with lugs, and one smaller three-over-one, divided light, wood window located on the first story.
Within the one-half-story gable there is one six-over-six light, wood window with lugs and a small, fixed wood window that appears to have been recently added. The windows are trimmed in wood casing, with a slightly projecting windowsill. There is also a gable vent that appears to be constructed of wood (Figure 6).
The board-formed concrete foundation is only slightly exposed along this elevation.
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
Figure 5. West elevation, facing north.
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
Figure 6. West elevation gable.
North Elevation
The current north elevation shows what remains of the rear shed addition (likely added to the house in ca. 1933), removed in 2024 (Figure 7 and Figure 8), was likely a sun porch or utility room. The shed addition consisted of a pair of windows on the north elevation, and a door. What remains is the section of an east facing wall (detailed within the east elevation section below). The original north elevation wall from the construction of the 1929 house consisted of a pair of windows, a single window, and two doors, one leading to the basement and another leading into the house; removed in 2024.1
1 Based on information provided by the City of Los Altos, this works was unpermitted.
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
Figure 7. North elevation, facing east.
Figure 8. North elevation, facing south.
East Elevation
The east elevation consists of the section of a wall, which was part of a small shed addition, no longer extant, except for the wall that is visible in Figure 8 and Figure 9, as well as the original side gable form. The
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
shed addition appears to have been clad in a combination of wood and aluminum clapboard and measured approximately 15 feet long by 6 feet wide. The walls that remain consisted of a pair of four-over and one single-hung, wood-clad vinyl windows. The original one-and-one-half-story portion of the east elevation consists of a pair of six-over-one, divided light, wood windows with lugs, and a smaller six-over-six, divided light, wood window (Figure 10). There is also a twelve-divided-light wood window near the southeast corner of the house, which appears to have been added later. The board-formed concrete foundation is exposed along this elevation (Figure 11).
Figure 9. Photograph showing a portion of an addition that was retained as part of a current project.
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
Figure 10. The east façade, facing south.
Figure 11. Photograph showing the board-formed concrete foundation is exposed along this elevation.
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
ca. 1933 Detached Garage
The ca. 1933 detached garage is not associated with any architectural style. The ca. 1933 detached garage is a simple side gable form with moderate pitched roof with “faux” gable returns on each gable end. The building is clad in wide wood boards and the roof is clad in asphalt shingles. There are what appear to be original wood and glazed hinged doors along the southern elevation (Figure 12); however, the doors are decorative, as the opening has been filled in – allowing for the use as a cottage. In 1994, the building was converted to a “cottage”; however, it may have been used for housing prior to 1994. Fenestrations include one six-light, wood, fixed window, a pair of six-light, wood, hopper windows, two single, six-light, hopper windows, one double-hung, wood window with lugs, one four-over-four-light, single-hung, wood-clad vinyl window, and a modern single entrance door (Figure 13). The building appears to rest on a concrete slab foundation. A modern deck extends the length of the north elevation.
Figure 12. South elevation, facing north.
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
Figure 13. Photograph showing the north and east elevations, facing southwest.
Landscape
The landscape consists of shrubs and trees, including pine and oak trees (Figure 14 and Figure 15).
Approximately 75% of the front yard is covered in hardscape, including pavers and a concrete and brick driveway, and concrete block planter beds. There is wooden fencing along the north, west, and east perimeter of the property, and wood and metal privacy fencing in the backyard along the southwest corner of the ca. 1933 detached garage.
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
Figure 14. Frontyard, facing northeast.
Figure 15. Backyard, facing northeast.
California Register of Historical Resources (CRHR) Evaluation
1. (Event): Is associated with events that have made a significant contribution to the broad
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
patterns of California’s history and cultural heritage.
The property, including the 1929 house, ca. 1933 detached garage, and landscape, was not found to be associated with any event that made a significant contribution to California’s history and cultural heritage.
Therefore, the property, including the 1929 house, ca. 1933 detached garage, and landscape, is not individually eligible for listing in the CRHR under Criterion 1.
2. (Person): Is associated with the lives of persons important in our past.
A thorough literature search and review of the property owners and occupants was completed; however, the research did not reveal any person associated with the Property that is important to our past who is eligible for listing on the CRHR.
Therefore, the property does not appear individually eligible for listing in the CRHR under Criterion 2.
3. (Construction/Architecture): 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.
Architecture: The 1929 house is associated with Colonial Revival architecture, with a period of significance of 1929. The 1929 house consists of elements of the Colonial Revival design, including the side-gabled one-and-one-half-story form, wood clapboard siding, divided light wood windows, and symmetrical primary façade. Although the building is constructed in the Colonial Revival style, it does not embody the distinctive characteristics of Colonial Revival architecture and is not representative of the design. In addition, it does not embody a method of construction and does not represent the work of an important creative individual or possess high artistic values.
The ca. 1933 detached garage, and landscape are not associated with any style architectural landscape design or landscape planning.
Therefore, the 1929 house, ca. 1933 detached garage, and landscape within the Property do not appear to be individually eligible for listing in the CRHR under Criterion 3.
4. (Information potential): Has yielded, or may be likely to yield, information important in prehistory or history.
Criterion 4 most commonly applies to resources that contain or are likely to contain information on an important archaeological research question. While most often applied to archaeological sites, Criterion 4 can also apply to built environment resources that contain important information. For a building to be eligible under Criterion 4, it must be a principal source of important information, such as exhibiting a local variation on a standard design or construction
DPR 523L (Rev. 1/1995)(Word 9/2013)
State of California Natural Resources Agency Primary#
DEPARTMENT OF PARKS AND RECREATION HRI #
Trinomial
CONTINUATION SHEET
Property Name: __81 Pepper Drive
technique can be eligible if a study can yield important information, such as how local availability of materials or construction expertise affected the evolution of local building development.
The 1929 house does not appear to be able to convey important information about Colonial Revival architecture. As such, the 1929 house, ca. 1933 detached garage, and landscape within the property are not eligible for listing in the CRHR under Criterion 4.
*Map Name: Mountain View *Scale: 1:24,000 *Date of map: __1991___________ DPR 523J (Rev. 1/1995)(Word 9/2013) * Required information State of California Natural Resources Agency Primary #
DEPARTMENT OF PARKS AND RECREATION HRI#
LOCATION MAP Trinomial
170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Imagining change in historic environments through
design, research, and technology
MEMORANDUM
DATE June 16, 2025 PROJECT
NO.
25162
TO Brittany Whitehill, AICP
Senior Planner
PROJECT City of Los Altos
OF City of Los Altos FROM Jen Hembree, Cultural Resource Planner, Page & Turnbull; and
Stacy Kozakavich, Project
Manager, Page & Turnbull
CC Christina Dikas Brobst, Principal,
Page & Turnbull
VIA Email
REGARDING 81 Pepper Drive HRE: Peer Review
INTRODUCTION
Page & Turnbull prepared this memorandum at the request of the City of Los Altos (City) regarding the property located at 81 Pepper Drive (APN 170-41-007) in Los Altos. The property is not currently listed in the most recent version available of the State of California Office of Historic Preservation (OHP) Built Environment Resources Directory (BERD) for Santa Clara County, issued in September 2022. It is not listed in the California Register of Historical Resources (California Register), or in the National Register of Historic Places (National Register). The property was found eligible for listing at the local level in 2011 as part of the Los Altos Historic Resources Inventory Update and was subsequently designated as a Historic Resource in the Los Altos Historic Resources Inventory (HRI). A Standards Compliance Review prepared in 2024 by Treanor identified character-defining features of the residence, but did not reevaluate the property’s significance. In April 2025, historic preservation consultant Evans & De Shazo, Inc. evaluated the potential historic significance of 81 Pepper Drive and prepared a 2025 Historic Resource Evaluation (2025 HRE) along with State of California Department of Parks & Recreation (DPR) 523A (Primary Record) forms for the property (hereafter referred to as the 2025 DPR 523 Forms), which were appended to the 2025 HRE and include the same information as the 2025 HRE. The 2025 HRE evaluation found that the property was ineligible for listing at the state or local level and recommended its removal from the HRI. Page & Turnbull peer reviewed the 2025 HRE and prior materials to provide our professional opinion on the adequacy of the physical description, background research, historic context, and appropriateness of the finding. Additional information and Page & Turnbull’s professional opinion regarding eligibility is also provided.
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 81 Pepper Drive is located just east of downtown Los Altos, on the north side of Pepper Drive between South San Antonio Road to the west and Eleanor Avenue to the east within the North Los Altos neighborhood (Figure 1 through Figure 3). The approximately 0.23-acre parcel includes a house built in 1929 and a ca. 1929 detached garage which has been renovated for use as a cottage. 1 Figure 1. Aerial view of subject property, 2025. Parcel indicated in pink.
Source: County of Santa Clara
Figure 2:. 81 Pepper Drive Assessor’s Map dated 2024-2025. Parcel boundary indicated in red.
Source: County of Santa Clara, edited by Page &Turnbull. 1 Dates of construction are based on Page & Turnbull research, which indicates that it appears to be more accurate to state the house dates to 1929 and the detached garage/cottage dates to ca. 1929.
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Figure 3. Site plan of 81 Pepper Drive, current footprint of house and cottage shaded red. Outline of shed addition (since mostly removed) in yellow. Source: GoogleEarth, 2022, edited by Page & Turnbull. 2022 imagery used due to clarity.
METHODOLOGY
Page & Turnbull reviewed the following documents in preparation of this memorandum:
• Circa: Historic Property Development, State of California Department of Parks & Recreation (DPR) 523A and 523B forms, dated June 8, 2011.
• Treanor, 81 Pepper Drive, Los Altos, CA Standards Compliance Review,’ dated September 20, 2024.
• Evans & De Shazo, Inc., A Historic Resource Evaluation and Updated Local Assessment of the Property Located at 81 Pepper Drive, Lost Altos, Santa Clara County, California, (Updated April 21, 2025) (Attachment A)
house
cottage
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 • DPR 523A Form for 81 Pepper Drive, Los Altos, Evans & De Shazo, Inc., recorded January 13, 2021 and attached as an appendix to the 2025 HRE. (Attachment A) Page & Turnbull conducted a site visit of the subject property on May 19, 2025 to take photographs and observe existing conditions. As per the executed contract with the City of Los Altos dated May 13, 2025, where additional research or analysis needs were identified, as outlined in the Peer Review sections that follow, Page & Turnbull conducted supplemental research and has provided additional information. Research regarding the subject property was conducted using online databases including Newspapers.com, the UC Santa Barbara Library FrameFinder historic aerial photograph website, HistoricAerials.com, San Francisco Public Library’s Fire Insurance Maps Online (FIMo) website and Ancestry.com. Site photographs in this report were taken by Page & Turnbull on May 19, 2025 unless otherwise noted.
BRIEF PROPERTY DESCRIPTION
The property at 81 Pepper Drive is a one-and-a-half story, Colonial Revival style residence, more commonly referred to as a ‘Cape Cod cottage.’ It has a side gable roof featuring three gabled dormers containing multi-light wood windows on the front facade along with a dentiled cornice and eave returns at its side gables. The roof is clad with contemporary composition shingles while the exterior walls are clad in wood clapboard siding. The front façade contains symmetrically balanced fenestration consisting of double-hung, multi-light wood windows with false shutters, paired at first floor and flanking a centered front door. The front door is paneled with sidelights, all of which are framed by simple wood trim and sheltered by a contemporary arbor/trellis. A stucco-clad chimney with brick coping pierces the eastern portion of the gable peak. A small rear shed addition at the northeast corner of the house has been partially removed, with only its east wall remaining. A sidegabled detached garage/cottage is set back and to the northwest corner of the property. (Figure 4, Figure 5, Figure 6, Figure 7, and Figure 8.)
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Figure 4. South (front) façade, view north.
.
Figure 5. North façade, view southeast. Red arrow
indicates east wall of partially removed shed addition Figure 6. Long view of south façade of property from Pepper Drive. Roof of garage/cottage indicated by
red arrow.
Figure 7. Garage/Cottage at northwest corner of
property, south façade.
Figure 8. Garage/Cottage at northwest corner of
property, east and north facades.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 PEER REVIEW OF 2025 HISTORIC RESOURCE EVALUATION
The following sections provide Page & Turnbull’s opinion on the adequacy and findings of the sections comprising the 2025 Historic Resource Evaluation. They are organized to match the organization of the 2025 HRE report and when appropriate, include recommendations and/or additional information and analysis.
Table of Contents and Report Organization
A table of contents is provided as is appropriate per industry standards.
DISCUSSION
The organizational structure of the contents differs from that which is outlined in the California Office of Historic Preservation’s (OHP) online manual, Instructions for Recording Historical Resources. 2 This OHP guidance document outlines the level of documentation and information required for recording and evaluating sites and individual resources for eligibility or inclusion in, for example, the California Register. Based on this OHP published guidance and Page & Turnbull’s professional experience, we recommend that an historic resource evaluation report begin with an introduction, methodology and a high-level summary of findings. This overarching introduction should be followed by brief discussion of the resource’s existing historic status (if any), which is then best followed by the complete physical description of the resource. The discussion of any related historic context(s) as applicable is most suitable after having provided a full description of the existing conditions of the resource, supported by photographs. As per the Instructions for Recording Historical Resources, subsequently, a discussion of whether the resource being evaluated meets the criteria of significance in relation to the historic context(s) concludes the report. No further comments related to the organizational structure of the 2025 HRE will be provided.
Introduction
The introduction of the 2025 Historic Resource Evaluation provides a brief overview of the property and outlines its existing historic status. A proposed project at the property is referenced, which implies the context of the evaluation preparation. The introduction references the applicable California Code of Regulations and Public Resources Code sections and hence, framework that the evaluation was completed under and includes the professional qualifications of the preparer. The primary author of the 2025 HRE, Stacy De Shazo, Principal Architectural Historian at Evans & DeShazo, appears to be an appropriately qualified architectural historian to prepare this assessment. Per the Evans & De Shazo website, she has a master’s degree in Historic Preservation from Savannah College of Art and Design and over 20 years of experience in the historic 2 https://ohp.parks.ca.gov/pages/1054/files/manual95.pdf.
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 architectural and cultural resources survey, identification, and evaluation in California, Oregon, Washington, and Alaska.3
DISCUSSION
Page & Turnbull notes that the introduction does not explain why the title page of the 2025 HRE indicates that it was initially prepared on March 4, 2025, but “updated, April 21, 2025.” Page & Turnbull recommends an explanation or at least acknowledgement that the HRE was subsequently updated after initial preparation be included in the introduction.
Location
The location section of the 2025 HRE provides the street address, the Assessor Parcel Number (APN) of the property, the parcel size, linear distances from nearby streets, and provides the property location on a USGS 7.5 quadrangle map.
DISCUSSION
A more precise location map is not provided within the 2025 HRE, though one is included in the appended DPR 523A forms. Page & Turnbull recommends that a location map that provides more specific existing contextual information (e.g., the immediate surroundings), such as that seen in Figure 1 and Figure 2 (above) be provided, in addition to the USGS quadrangle map.
Regulatory Setting
The regulatory setting of the 2025 HRE explains the overall nature of California Environmental Quality Act (CEQA) as it applies to cultural resources, including those that may be classified as “buildings” as defined by Cal. Code Regs. Tit. 14, § 4852. California Code Regs. § 15064.5 is cited to outline the criteria for listing in the California Register and therefore when a cultural resource shall be considered “historically significant” by a lead agency, such as the City of Los Altos [Community Development Department]. The regulatory setting section of the 2025 HRE also describes from a local regulatory perspective why the 2025 HRE was prepared. This section indicates that the City of Los Altos requested an updated “local” evaluation of the property. Thus, the City of Los Altos Criteria for Designation as per Municipal Code Chapter 2. Historic Preservation Section 12.44.040 is outlined.
DISCUSSION
Although the regulatory setting section includes the applicable state regulatory language, Page & Turnbull recommends adding a statement explaining the need from the CEQA perspective for the preparation of this 2025 HRE. For example, Page & Turnbull understands that CEQA applies to 3 See: https://www.evans-deshazo.com/#/owners.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 “projects” proposed to be undertaken or requiring approval from state or local government agencies. Historic and cultural resources are considered to be part of the environment. Because the property was designated as a Historic Resource in the Los Altos Historic Resources Inventory, the property would be considered a historical resource for the purposes of CEQA review of potential projects which are subject to this state legislation.
Methods
The methods section of the 2025 HRE explains the actions the preparer took to investigate and research the property, including how and from what sources or repositories or field surveys information was collected. The methods Evans & De Shazo, Inc. utilized are consistent with industry standards.
DISCUSSION
However, the date the architectural survey conducted by the preparer is not indicated in this section; it is indicated only later in the document on Page 31. Page & Turnbull recommends the date be provided in the methods section for temporal context between the date of the survey and the date the 2025 HRE was prepared. It is important to demonstrate that the existing conditions observed at the time of the site visit, including new or in-progress alterations, accurately reflect the conditions of a property at the time of the evaluation.
Historical Setting
The historic setting section of the 2025 Historic Resources Evaluation provides a brief history of the geographical area where the property is located. The section begins with the history of the general area that is now referred to as Los Altos specifically from the years 1822 (during Mexican rule) to the 1850s. The establishment of and subsequent history of the development of Los Altos from the 1870s, when it consisted of small and large farms, to 1890, when larger farms and cattle ranches were subdivided and sold as smaller farms, through the early 1900s, when land development and transportation companies began buying land in Los Altos and subdividing them as part of planned developments. A broad discussion of Los Altos through the decades spanning the 1930s, 1940s, 1950s, and 1960s through the 1970s then follows.
DISCUSSION
The history of the property’s more localized neighborhood is not discussed. Providing the history of the property’s ‘place’ from the broad (county, city, or town) to specific environs (neighborhood or development area) is industry standard as it thereby establishes an historic context for the property.
The formalized establishment of Los Altos as a town is also not clarified. Understanding this relative to the subject property’s neighborhood’s establishment, if available/as applicable, and/or the
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 property’s date of construction would assist in placing the property in appropriate developmental context. Page & Turnbull therefore recommends including specificity to the establishment of Los Altos as a town or city, as well as to the historical development of commercial and/or residential construction in the fledgling community and/or property’s immediate neighborhood, as applicable.
For example, according to the 2012 City of Los Altos Historic Resources Inventory:
Many believe that the real beginning of Los Altos start[ed] with the Altos Land Company and acquisition of Sarah Winchester’s 100 acres in 1906. This land became what is known today as the downtown triangle…the creation of a new town-site to be called “Banks and Braes.” Just when the name was changed to Los Altos in unknown, but we do know that the Altos Land Company and the University Land Company were formed in 1907...With the establishment of the town in 1907 came the beginnings of subdivisions (although a few earlier subdivisions were recorded prior to 1907)…By 1911, according to Eastman’s history of the town, Los Altos had only fifty homes; by 1913, only thirty-two telephones had been connected. The majority of properties in the residential context are homes built in the 1920s and 30s, reflecting the growth of the area. By this period, the central business district had been established, roadways were more complete, and working-class families could afford to move to “the county” and grow a few apricot trees. The dominant house types in this category include:
Bungalows, Mission, Period Revival (Tudor, Colonial, Provincial), Prairie, Italian Villa, Spanish Colonial Revival.
4 The central business district is a six-block triangle bound by San Antonio Road to the east, Foothill Expressway to the west, and West Edith Avenue to the north. The subject property is situated on Pepper Drive on a block immediately east of San Antonio Road near to the southern portion of the central business district.
Property History
This section of the 2025 HRE describes the history of the subject property, beginning when it was acquired as part of a much larger expanse by the United States government in 1848, subsequently surveyed by 1865 and ultimately subdivided, first as part of the L.S. Clarke Subdivision (1895) and then as part of the Adams Subdivision (1920). Plat maps showing these subdivisions with the property’s location within them are included. Early aerial imagery dating to 1930, appears to show the house, and a 1939 aerial photograph that appears to show both the house and the detached garage/cottage are included.
4 https://www.losaltosca.gov/sites/default/files/fileattachments/historical_commission/page/36161/hri_section_ii_historic_cont ext.pdf
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 The property history section also includes a table (referred to as Table 1) that lists the owners and occupants of the property beginning in 1928, upon the initial owner’s acquisition of the parcel and construction of the current house, through to 1993. The table incorporates biographical information available regarding the owners as determined via historical newspaper articles and records on the genealogical site, Ancestry.com. The property history section also includes an image of a news article announcing the completion of the 1929 home, as well as a news article showing a portrait of the original owner’s family. The Property History section subsequently includes tables outlining the property’s available permit history, which spans from 1994 to 2024.
DISCUSSION
The historic aerial photographs provided in the 2025 HRE property history section are pixelated and difficult to discern. Page & Turnbull recommends only including imagery that is a high resolution and discernible. Page & Turnbull also recommends completing the owners/occupants table (Table 1) to include all transfers up to and including the current ownership.
Table 1 of the 2025 HRE states: “In ca. 1933, the detached garage was constructed (Figure 16), likely by Harry. During this time, it appears the rear shed addition was added to the northeast corner of the house.” However, a historical source which supports this date of construction or further explanation of how the determination of the year ca. 1933 was made is not provided. Rather, the referenced Figure 16 is an aerial image dated to 1939. Page & Turnbull recommends, therefore, clarifying how the ca. 1933 date for construction of the detached garage/cottage was determined.
Page & Turnbull acknowledges that Sanborn Fire Insurance Maps do not encompass the Pepper Drive block and that many historic aerials are often difficult to discern, regardless of resolution.
In contrast to the 2025 HRE’s assumed date of construction for the garage, Treanor’s 2024 Standards Compliance Report for the property states “the outbuilding appears on a 1948 aerial, but was likely constructed as a detached garage at the time the house was built.”5 In addition, a 1929 newspaper article included in the 2025 HRE property historic section mentions that the original owners/occupants (the Van Epps) were “occupying temporary quarters on the property,” while their new home was under construction.6 Based on a high resolution version of the 1930 historic aerial photograph (Figure 9), Page & Turnbull suggests that the existing detached garage/cottage was indeed already present and was the structure serving as the owner’s temporary residence. In a clearer version of the 1939 historic aerial photograph (Figure 10), the detached garage/cottage at the northwest area of the property is also present. Page & Turnbull concurs with the 2025 HRE that 5 Treanor, “81 Pepper Drive, Los Altos, California Standards Compliance Report,” dated September 20, 2024, 4. 6 The Peninsula Times Tribune, “To Occupy New Home,” July 15, 1929.
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 the construction of the small rear addition attached to the northeast corner of the house, which does not appear to exist in the earlier image, likely dates to ca. 1939. Page & Turnbull would therefore clarify that the detached garage/cottage dates to ca. 1929 and the house dates definitively to 1929, while the rear addition to the house dates to ca. 1939.
Figure 9. 81 Pepper Drive, 1930. Parcel outlined in red with house and what appears to be the detached ‘garage’ at rear. Source: University of California Santa Barabara Flight C_1180, Frame 9, 1930. Parcel boundary and notations added by Page & Turnbull.
house
cottage
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Figure 10. 81 Pepper Drive, 1939. Parcel outlined in red with house, detached garage/cottage and rear addition.
Source: University of California Santa Barabara Flight C_5750, Frame 286-9, 1939. Parcel boundary and notations added by Page & Turnbull.
Page & Turnbull also recommends indicating that the permit information has been compiled from written records held by the City of Los Altos and that permit records did not include the original date of construction nor the original builder or architect for the primary residential building, nor did they include information related to the construction of the detached garage/cottage. Page & Turnbull further recommends that the property history section include the entire chronology of the property to present, including information related to any ancillary structures built prior, later, or later removed from the site, such as the detached garage / cottage. In addition, other elements of the construction chronology that can be compiled through analysis of aerial photographs, maps, other cottage
rear addition
house
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 historic images, news articles, as well as visual inspection, as available, are recommended to be described. Page & Turnbull recommends indicating that apart from the approved permits, dated 1994 and 1999, no other changes were formally documented by permit or other available sources.
A visual analysis of the building’s form and materiality by Page & Turnbull shows that the house’s ca. 1939 shed addition at the northeast corner of the house has been partially removed, with only its east wall remaining. This shed addition appears to have been partially removed sometime between 2023-2024 based on aerial imagery. The north wall of the house has, as a result, also been stripped of its cladding and cornice. Extending from the north wall is a concrete slab on grade with unfinished wood decking, evidencing the initiation of construction of a new rear addition (since paused). Visual inspection of the house also indicates that exterior doors on the house appear to be non-original, including the paneled primary entry door on the front facade, as well as the sliding doors on the rear (north) façade. A contemporary arched arbor has been installed at the front entrance as well and has been present since at least 2007 based on available street-view imagery. Vinyl windows are located on the remaining east wall of the shed addition, likely having replaced earlier multi-lite wood windows.
A detailed construction chronology should also include a history of other site components, if extant.
Thus, Page & Turnbull recommends that the following additional construction history of the detached garage/cottage and the overall site be included as well. No known formal documentation of changes to the garage/cottage exist; an application to convert the building to a legalized accessory dwelling unit in 2024 was not approved. However, visual inspection indicates the ancillary building has undergone changes over time. A contemporary entry door is located on the south façade, leading to a contemporary wood deck. Decorative, fixed paired doors are installed in a large, possibly former garage opening on the north façade. Although most windows are wood, they appear to vary in size and type from one-over-one hung window, six-light hopper windows, four-over-four hung window, evidencing the ad-hoc construction and/or alterations of the building. The garage/cottage has a replacement asphalt shingled roof, likely installed at the same time as the that of the house in the 1990s per a roofing permit.
Page & Turnbull research indicates the bounds of property have not changed since the residence’s construction, and aerial imagery indicates the site has always included both a front and rear yard, with hardscape area or driveway along the western side leading to the detached garage/cottage. The driveway today is of concrete with brick accents, while immediately south of the garage/cottage the area has received contemporary cobblestone pavers. Wooden fencing is located along the north, west, and east perimeter of the Property, portions of which appear to have been installed along the west at an unknown date between 2007 and 2011, based on street imagery. Prior to 2015, too, a short picket fence also delineated the front yard from the street.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Architectural Context
The architecture section of the 2025 Historic Resource Evaluation discusses the history and identifying features associated with the Colonial Revival architectural style in America. The 2025 HRE indicates that the 1929 house on the property is reflective of this particular style and therefore, as is industry standard, the section establishes an historic architectural context for the property. The 2025 HRE appropriately references Virginia McAlester’s, A Field Guide to American Houses, 2014 edition, which is considered the definitive guide to residential architecture in America.
The 2025 HRE states that residences designed in the Colonial Revival style typically include the following characteristics:
1. “Symmetry in façade – although 10% of Colonial Revival were asymmetrical.
2. Hipped or gabled roofs with boxed eaves.
3. Fanlights and/or sidelights around main door.
4. Double-hung sash windows, often set in pairs.
5. Clapboard and brick exterior cladding.
6. Classical detailing (sometimes exaggerated), including pediments, columns or pilasters leading to elaborate entries.”
In addition, the 2025 HRE indicates there are subtypes of the style that include Asymmetrical, Hipped Roof with Full-Width Porch, Hipped Roof without Full-Width Porch, Side Gable Roof, Centered Gable, Gambrel Roof, Second-Story Overhang, One-Story, Three-Story and Built-In Garage.
DISCUSSION
The Colonial Revival context could be expanded to provide further description of certain detailing typically featured in Colonial Revival style. For instance, per the 2023 edition of A Field Guide to American Houses, typical of many Colonial Revival roof cornices is that they are almost always part of a boxed roof-wall junction with little overhang and are frequently decorated with dentils or modillions; some may have open eaves and rake. In addition, windows are usually rectangular and hold multi-pane glazing in one or both sashes.7 It is also noted that masonry predominates in highstyle Colonial Revival examples whereas vernacular examples were generally of wood before about 1920, with masonry progressively becoming more common as veneering techniques became widespread in the 1920s.
8 7 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), 412. 8 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), 412.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Page & Turnbull also recommends the architectural context section provide further clarification on the applicable subtype(s) to the property, particularly the one-story subtype, of which the property at 81 Pepper Drive most closely resembles, and which according to McAlester, are generally known as “Cape Cod cottages.”9
A Field Guide to American Houses defines the one-story subtype of Colonial Revival or Cape Cod cottage as follows:
One-Story Subtype – ...”one-story Colonial Revival houses are also common. These are generally Cape Cod cottages, loosely patterned after early wooden Cape Cod folk houses of eastern Massachusetts, usually with the addition of Georgian or Federalinspired doorways. These were built throughout the Colonial Revival era but were particularly common in the 1940s…”10 McAlester also indicates, “The Cape Cod is the most common form of one-story Colonial Revival house. As a form, it originated in the early 18th century and continued with few changes through the 1950s.”11 In addition, Page & Turnbull recommends that images of properties that exemplify the One-Story or Cape Cod cottage subtype, as shown in A Field Guide to American Houses, be provided to visually explain the property’s architectural context. As seen in figures below, despite these examples’ moniker of one-story, they are side-gabled and have dormers at an upper level or half-story, not unlike the property at 81 Pepper Drive (Figure 11, Figure 12).”12 9 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), pp. 411-12. 10 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), 412. 11 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), 427. 12 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), 427.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Colonial Revival – One-story Subtype – Excellent Examples Figure 11. One-story subtype example, ca. 1920s.
Source: A Field Guide to American Houses, 2023 reprint
edition, p. 427.
Figure 12. One-story subtype example, 1929.
Source: A Field Guide to American Houses, 2023
reprint edition, p. 427.
The 2025 HRE does not include a comparative analysis. It is typically industry standard to compare a property to comparable works of the relevant architectural style and era. In this case, comparable works of Colonial Revival style, single-family residential architecture built in the early 20th century, especially the one-story or ‘Cape Cod cottage,’ and typically within the general vicinity of the subject property would be compared. It is important to “compare the resource with others that belong to the same property type and relate to the same historic context” because “it will help establish the significance of the resource,” or will help provide a clear rationale to support an ineligible finding.13 Page & Turnbull provides herewith several examples of Colonial Revival style architecture residential homes constructed in the early 20th-century located within the general vicinity of the subject property, both of which have been designated as local historic resources or local historic landmarks by the City of Los Altos. These properties were determined by reviewing the list of Los Altos Historic Landmarks and the list of Los Altos Historic Resources in conjunction with the OHP Built Environment Resources Directory (BERD) for Santa Clara County, issued in September 2022 as well as through visual analysis using online street imagery.14 13 https://ohp.parks.ca.gov/pages/1054/files/manual95.pdf. 14 https://www.losaltosca.gov/historicalcommission/page/historic-inventory; and OHP BERD – County of Santa Clara, https://ohp.parks.ca.gov/pages/1068/files/Santa%20Clara.csv
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Table 1: Single-Family Residential and Colonial Revival Style Homes Address Style Est. Year of
Construction*
Designation
1448 Fowler
Lane
Dutch Colonial Revival / Gambrel
roof
1900 Los Altos Historic Landmark
1570
Kensington
Circle
Colonial Revival / Side-Gabled 1922 Los Altos Historic Resource *Year of Construction from State of California Office of Historic Preservation Built Environment Resource Directory or Santa Clara County assessor
Page & Turnbull notes that per the National Register, an excellent example of an architectural style “must clearly contain enough of those characteristics to be considered a true representative of a particular type, period, or method of construction.”15 Based solely on visual analysis of current street view photography, Page & Turnbull thus augments the comparative analysis list with the following discussion of characteristics of the known Colonial Revival-style examples. It should be noted that Page & Turnbull has not conducted a comprehensive construction history of these properties.
Figure 13. 1448 Fowler Lane. Source: Google Streetview
15 National Register Bulletin No. 15: How to Apply the National Register Criteria of Evaluation, https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Figure 14. 1570 Kensington Circle Source: Google Streetview. • 1448 Fowler Lane, Figure 13, expresses the gambrel roof subtype, also referred to as Dutch Colonial Revival-style, featuring steeply pitched gambrel, containing a nearly full second story and separate dormer windows flanking a shed dormer above and accentuated front entry with a decorative crown supported by slender columns which form an entry porch. • 1570 Kensington Circle, Figure 14, expresses the side-gabled Colonial Revival style, featuring symmetrically-balanced windows, with the second floor hung windows containing multi-light panes in both sashes. Its front entry is accentuated and features a decorative crown supported by slender columns which form an entry porch.
In comparison to the comparable properties detailed above, both those in the surrounding area and those seen in A Field Guide to American Houses (all referenced above), Page & Turnbull finds that the design of 81 Pepper Drive, provides a modest example of the Colonial Revival style, in particular the one-story/’Cape Cod cottage’ subtype Figure 15.
The house at 81 Pepper Drive is one story with half-story above and features a side-gabled roof and is clad in wood siding (clapboard). The material palette and form are consistent with that of Colonial Revival one-story Cape Cod cottages, in particular vernacular and pattern-book examples.
Fenestration consisting of rectangular, double-hung multi-light windows, some with false shutters and set in pairs at the first floor, is symmetrically balanced. The wood windows have ogee lugs (Figure 18). The roof features gabled dormers and a cornice decorated with dentils and eave returns (Figure 16). The fenestration and roof detailing are typical of the Colonial Revival Cape Cod cottage.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 The front door, however, does not contain the decorative crown (pediment) supported by pilasters or slender columns to form a front porch normally exhibited in Colonial Revival architecture. Rather, the central front door is set with a flat surround with sidelights only (Figure 17). (The arbor/trellis is a contemporary installation.)
Figure 15. Primary (south) façade, view north.
Figure 16. Primary façade, detail of cornice with dentils and eave return.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Figure 17. Detail of front entry.
Figure 18. Detail of ogee lug on double-hung wood window.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Historic Architectural Survey
This section of the 2025 HRE provides a physical description of the existing property. The property’s existing components (at the time of the survey) including the house and detached garage/cottage, as well as the associated landscape or lawn are each described, as is their architectural style, if any.
Physical descriptions of each of the house, garage/cottage and landscape are accompanied by photo(s), yet there is a lack of an aerial image or site plan indicating the location of each of the two buildings on the property. The physical description otherwise generally adheres to industry standards.
DISCUSSION
However, the Instructions for Recording Historical Resources state that, “Descriptions of buildings, structures, and objects should identify construction details, materials, workmanship, and alterations.”16 Page & Turnbull typically therefore includes, following the physical description section, a detailed construction chronology specifically related to the building and, if applicable, other site components. This may include a building permit history, if available, and/or notations of alterations determined by field survey and/or analysis of historical maps, newspapers and/or photographs as available and/or some combination thereof. Page & Turnbull’s observations related to this have already been discussed above.
Evaluation for Historical Significance
The evaluation for historical significance section of the 2025 HRE indicates the context in which the property at 81 Pepper Avenue was evaluated by the preparer: Colonial Revival style architecture for the year of construction, 1929. An explanation of the California Register is subsequently provided in this section along with its relationship to the National Register and the similarities and differences in the guidelines between the two registries. Qualifications required for a property to be listed in the California Register are provided. The section indicates a property must possess significance under one of the four California Register criteria and have historic integrity to qualify for listing. The definition of historic integrity is also provided, indicating it consists of evaluating seven aspects that include location, design, setting, materials, workmanship, feeling, and association.
The property is then evaluated under each of the four California Register criteria and judged in relation to its historic contexts.
The 2025 HRE found that the property appears to be ineligible for California Register under all criteria. Because the property was recommended as ineligible for California Register listing, an 16 https://ohp.parks.ca.gov/pages/1054/files/manual95.pdf.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 integrity assessment and list of character-defining features was not included, per industry standards.
DISCUSSION
This section should also explain that the property was evaluated under the context of early 20th century development of the City of Los Altos (historical context). In addition, Page & Turnbull recommends explaining that the entire property was evaluated under the historical context and that only the house was evaluated under the architectural context, given the ancillary component (garage/cottage) of the property does not reflect any architectural style.
Page & Turnbull, however, concurs with the findings of the 2025 HRE that the property does not appear to be individually eligible for listing under California Register Criteria 1, 2, 3, and 4. Page & Turnbull summarizes the 2025 HRE findings below and provides supplemental information under the Criteria, as needed. The explicit definition of each Criteria, as provided by the California Register, is also included prior to the evaluation.
Criterion 1/ Events: It is associated with events or patterns of events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States.17
2025 HRE Finding: The 2025 HRE finds that the property, 81 Pepper Avenue, does not appear to be individually eligible for listing in the California Register under Criterion 1, as the property has not contributed to the broad patterns of history in Los Altos, the state, or the nation.
Page & Turnbull Discussion: The current house and garage/cottage at 81 Pepper Drive was constructed during the time when most properties in Los Alto’s residential context, as per the Los Altos Historic Resource Inventory, were constructed, that is, in the 1920s and 1930s, which was reflective of the growth of the area after its earlier (1907) establishment. By this time, the central business district had been established, roadways were more complete and families, including the working class, could afford to relocate to the town. The extant property at 81 Pepper Drive, was constructed at the end of the 1920s, later than other Colonial Revival-style residential buildings in the general vicinity (per Table 1 of this report). Although associated with the general trend of growth in the 1920s, the property is not specifically important and thus does not convey significance for its association with that particular growth period (Event). Furthermore, research did not identify that the property contributed to any other significant events or other patterns of local, state, or national cultural heritage.
17 Criterion definitions are provided by the California Register, https://ohp.parks.ca.gov/?page_id=21238.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Criterion 2/ Persons: It is associated with the lives of persons important to local, California, or national history.
2025 HRE Finding: As stated in the 2025 HRE, the property, 81 Pepper Drive, does not appear to be individually eligible for listing in the California Register under Criterion 2.
Page & Turnbull Discussion: The Harry P. Van Epps family owned the current property from its 1929 construction until 1945, however research did not identify that any family member having an association with the occupancy or ownership of 81 Pepper Drive was significant to the history of Los Altos, the state, or nation. According to the 1930 federal census, Van Epps was a carpenter in the “house building” industry. Given his trade, there is the possibility that Van Epps constructed the house and/or garage/cottage at 81 Pepper Drive, however, no documentary evidence was found to confirm this. The property subsequently changed ownership no less than ten times and research did not identify that persons important to local, California, or national history owned or occupied the property.
Criterion 3/Architecture: It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values. 2025 HRE Finding: As stated in the 2025 HRE, 81 Pepper Drive does not appear to be individually eligible for listing in the California Register under Criterion 3.
Page & Turnbull Discussion: The 1929 house exhibits some elements of Colonial Revival style, and particularly the one-story or Cape Cod cottage subtype (due to its form and massing), a subtype built throughout the Colonial Revival era and that became especially common in the 1940s. The house contains such Colonial Revival characteristics as a side-gabled roof, symmetrically balanced fenestration consisting of double-hung, multi-light windows with false shutters and paired at first floor with a centered front door. The roof features gabled dormers and a cornice decorated with dentils and eave returns. However, the house does not express the accentuated front door normally character-defining of Colonial Revival style, featuring a decorative crown supported by pilasters or slender columns to form a front porch. Rather, as a modest representation of the style, evidenced also through its wood cladding in lieu of masonry and lack of elaborate front entry, the house thus does not fully exemplify the distinctive characteristics of the Colonial Revival style required to be individually eligible for listing in the California Register, nor does it exemplify a method of construction, nor does it possesses high artistic values. And, as no architect of record is known, the house does not represent the work of a master.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Criterion 4/Information potential: Has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California or the nation. 2025 HRE Finding: As indicated in the 2025 HRE, the property at 81 Pepper Drive does not appear to be individually eligible for listing in the California Register under Criterion 4 as a building or property that has the potential to provide information important to the prehistory or history of the City of Los Altos, state, or nation.
The 2025 HRE clarifies that, “While most often applied to archaeological sites, Criterion 4 can also apply to built environment resources that contain important information. For a building to be eligible under Criterion 4, it must be a principal source of important information, such as exhibiting a local variation on a standard design or construction technique can be eligible if a study can yield important information, such as how local availability of materials or construction expertise affected the evolution of local building development.”
Page & Turnbull Discussion: Page & Turnbull concurs with the 2025 HRE finding, but recommends affirming that 81 Pepper Drive does not feature construction or material types, or embody engineering practices that would, with additional study, provide important information, and that evaluation of this property was limited to age-eligible resources above ground and did not involve survey or evaluation of the subject property for the purposes of archaeological information.
Local Assessment
The local assessment and recommendation section of the 2025 HRE indicates that the house is a local historic resource, and that an updated local assessment was requested to determine continued eligibility for local listing, inclusive of the house, garage/cottage and other site features. The 2025 HRE explains that Los Altos Municipal Code Section 12.44.040 outlines the three criteria for eligibility for local designation as a historic resource or historic landmark and that all three criteria must be met for a property to be eligible as a historic resource or historic landmark.
The 2025 HRE found that the property appears to be ineligible as a local historic resource or local landmark. Page & Turnbull concurs with the findings of the 2025 HRE that the property does not appear to be individually eligible for listing under the Los Altos Municipal Code Section 12.44.040.
Page & Turnbull summarizes the 2025 HRE findings below and provides supplemental information under the criteria, as needed. The explicit definition of each criterion, as provided by the Municipal Code, is also included prior to the evaluation.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 A. Age. A structure or property should be more than fifty (50) years in age. (Exceptions can be made to this rule if the building(s) or site(s) is/are truly remarkable for some reason - such as being associated with an outstanding architect, personage, usage or event).
As stated in the 2025 HRE, the property, 81 Pepper Drive, including its house and detached garage/cottage are over 50 years old. As such, the property meets the required local Criterion A.
B. Determination of Integrity. A structure or property should retain sufficient historic integrity in most of the following areas:
1.Design: The combination of elements that create the form, plan, space, structure and style of a property.
2.Setting: The physical environment of a historic property.
3.Materials: The physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property.
4.Workmanship: The physical evidence of the crafts of a particular culture or people during any given period in history or prehistory.
5.Feeling: A property's expression of the aesthetic or historic sense of a particular period of time.
Page & Turnbull understands that, as the 2025 HRE points out, for the purposes of National Register or California Register evaluations, integrity analysis is only completed if a building, structure, object, site, or district is found to be significant. As stated by the National Register, “Integrity is ability of a property convey its significance.”18 Therefore, if a property is not found significant under any area, then generally no integrity analysis is conducted.
However, in accordance with Los Altos Municipal Code Section 12.44.040 and thus, for the purposes of local evaluation, a determination of integrity as Criterion B for local eligibility is provided in the 2025 HRE prior to a finding of local significance. As stated in the Los Altos Historic Resources Inventory, “The evaluation process consists of three steps which are summarized below. The first step is to determine whether or not the property is over fifty years of age […] The next step is to determine whether the property retains enough original materials and features to convey its value as a historic resource […] If a resource meets the age requirement (or demonstrates the potential for exceptional significance) and retains 18 National Register Bulletin 15; How to Apply the National Register Criteria for Evaluation, 44; https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 physical integrity, the next step is to determine if the resource has historic significance.”19
The following sections address each aspect of integrity included in Criterion B for the local inventory, with a summary of the 2025 HRE’s findings followed by Page & Turnbull’s discussion.
1. Design: The 2025 HRE finds that the 1929 house remains intact, and modest elements of Colonial Revival design are present, but it lacks distinctive features including a prominent front entrance, consisting of columns or pilasters and therefore lacks the integrity of Colonial Revival design.
Page & Turnbull does not concur with the 2025 HRE’s assessment of design integrity. As stated, the house appears to retain its original 1929 side-gable form, and design elements include symmetrical fenestration consisting of rectangular, double-hung multi-light windows, some with false shutters and set in pairs at the first floor. The roof also continues to feature gabled dormers, and a cornice decorated with dentils and eave returns. It is not documented to have had an accentuated front entrance including a decorative crown supported by pilasters or columns to form a front porch, thus the lack of such does not lessen its integrity of design.
In Page & Turnbull’s professional opinion, thus, the house retains the integrity of its design as a single-family home built in 1929 in a modest Colonial Revival style. In addition, in Page & Turnbull’s professional opinion, the overall property, that is, the house, its garage/cottage and landscape also retain integrity of design. The spatial relationship between the house and garage and the front and rear yards remains intact.
2. Setting: The 2025 HRE finds that the 1929 house and its garage/cottage and landscape retain integrity of setting because, despite growth to Los Altos overall, the immediate environment remains a small neighborhood with modest-sized houses set back from the street and designed in a variety of styles.
Page & Turnbull concurs with the assessment that the property retains integrity of setting.
3. Materials: The 2025 HRE finds that the 1929 house retains the original wood clapboard siding on three of the four elevations; ten divided light wood windows; two paired, divided light windows; and wood shutters on the primary façade appear to be original from 1929 and that therefore the house retains integrity of materials. The 2025 HRE 19 https://www.losaltosca.gov/sites/default/files/fileattachments/historical_commission/page/36161/hri_full_doc.pdf, Page I-1.
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 also finds that the ca. 1929 garage/cottage retains a reduced integrity of materials although its exterior cladding and some windows appear original.
Page & Turnbull concurs with the general assessment that the house and garage/cottage retain integrity of materials.
4. Workmanship: The 2025 HRE finds that the workmanship evident on the house does not show any special skill in Colonial Revival design, as it does not include the Classical detailing (sometimes exaggerated), including pediments, columns or pilasters leading to elaborate entries, which is where workmanship is often showcased through handtooling, carving, painting, or joinery.
Page & Turnbull does not concur with this assessment. As stated in the 2025 HRE, “the workmanship evident on the 1929 house is very modest,” and “…the wood windows with lugs show workmanship.” Page & Turnbull would argue that therefore the physical evidence of workmanship, as defined by the Municipal Code remains. Moreover, the National Register provides guidance on how to evaluate the integrity of a property and states that workmanship can be expressed in vernacular methods of construction and plain finishes or in highly sophisticated configurations and ornamental detailing.”20 The lack of sophisticated configurations therefore does not indicate a lack of workmanship. The use of standardized window sash, dentils, shutters, and wood siding does reflect workmanship evidencing the “applications of both technological practices and aesthetic principles,”21 in this instance, the technological advance of mass milling production of the time. In Page & Turnbull’s professional opinion, the house therefore retains integrity of workmanship.
5. Feeling: The 2025 HRE finds that because the house was not intended to meet the grander expectations of a Colonial Revival house, it fails to evoke the architectural details and spirit of the style, it does not retain integrity of feeling.
Page & Turnbull does not concur with this assessment. The definition of feeling according to the Municipal Code is the expression of the aesthetic or historic sense of a particular period of time. As stated in the 2025 HRE and to which Page & Turnbull agrees, the 1929 house is a modest example of Colonial Revival architecture. As Page & Turnbull furthered, it is a modest example of a Colonial Revival one-story/’Cape Cod cottage’ subtype. Although not an excellent example of the Colonial Revival style, given the lack of an accentuated and more elaborate front entry, the house does appear to express the aesthetic of a modest Cape Cod cottage of the 1920s and therefore retains integrity of feeling.
20 National Register Bulletin 15; How to Apply the National Register Criteria for Evaluation, 45; https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf 21 National Register Bulletin 15; How to Apply the National Register Criteria for Evaluation, 45; https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf
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PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 As such, in Page & Turnbull’s professional opinion, the Property’s 1929 house meets all requirements of local Criterion B. In Page & Turnbull’s professional opinion, the Property’s ca. 1929 detached garage/cottage and landscape do not meet the required local Criterion B.
C. Historic Significance. A structure or property should be clearly associated with one or more of the following areas of significance:
1.Event: Associated with a single significant event or a pattern of events that have made a significant contribution to broad patterns of local or regional history, or cultural heritage of California or the United States;
2.Person/People: Associated with the lives of persons important to the local, California or national history;
3.Architecture/Design: Embodies the distinctive characteristics of a design-type, period, region or method of construction, or represents the work of a master or possesses high artistic value; or
4.Archaeology: Yields important information about prehistory or history of the local area, California or the nation.
1. Event: The 2025 HRE finds that the property does not appear to be clearly associated with any event that have made a significant contribution to broad patterns of local or regional history, or cultural heritage of California or the U.S. for local listing Page & Turnbull concurs with the findings of the 2025 HRE that the property does not meet the required local Criterion C under Event but provides the following clarification. Although the 1929 house is associated with the general trend of growth in Los Altos during the 1920s, the property is not specifically important to this trend and thus does not convey significance for its association with that particular growth period.
2. Person/People: The 2025 HRE finds that the property does not appear to be clearly associated with the lives of persons important to the local, California or national history.
Page & Turnbull concurs with the findings of the 2025 HRE that the property does not meet the required local Criterion C under Person/People but provides the following clarification. Although, the original owner/occupant of the house, Harry Van Epps, was a carpenter in the “house building” industry, no documentary evidence was found to confirm his hand in the construction of the 1929 home. The property subsequently changed ownership no less than ten times and research did not identify that persons important to local, California, or national history owned or occupied the property.
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154
3. The 2025 HRE The 2025 HRE acknowledges that the 1929 house is associated with Colonial Revival architecture but states it does not embody the distinctive characteristics of Colonial Revival architecture, does not embody a method of construction and does not represent the work of a master or possess high artistic values.
Page & Turnbull concurs with the findings of the 2025 HRE that the property does not meet the required local Criterion C under Architecture/Design but provides the following clarification. Page & Turnbull acknowledges that the 1929 house exhibits elements of Colonial Revival style and particularly exhibits the one-story or Cape Cod cottage subtype (due to its form and massing), a subtype built throughout the Colonial Revival decades and that became especially common in the 1940s. The house contains such Colonial Revival characteristics as a side-gabled roof, symmetrically balanced fenestration consisting of double-hung, multi-lite windows with false shutters and paired at first floor with a centered front door. The roof features gabled dormers and a cornice decorated with dentils and eave returns. However, the house does not express the accentuated front door which is typically character-defining of houses in the Colonial Revival style, featuring a decorative crown supported by pilasters or projecting slender columns to form a front porch. Rather, as a modest representation of the style, evidenced also through its wood cladding in lieu of masonry and lack of elaborate front entry, the house thus does not fully exemplify the distinctive characteristics of the Colonial Revival style required to be individually significant, nor does it exemplify a method of construction, nor does it possesses high artistic values. And, as no architect of record is known, the house does not represent the work of a master.
4. Archeology: The 2025 HRE states the Property was not assessed for archaeology.
The evaluation of this property was limited to age-eligible resources above ground and did not involve survey or evaluation of the subject property for the purposes of archaeological information and thus, the property does not yields important information about prehistory or history of the local area, California or the nation. As such, Page & Turnbull concurs with the 2025 HRE that the Property, inclusive of the 1929 house, ca. 1929 detached garage/cottage and landscape do not meet the required local Criterion C under Archeology.
Recommendation
The 2025 HRE recommendation section indicates that because the house has lost integrity and/or historic significance, the house is recommended to be removed from the Los Altos Historic Resource Inventory. The 2025 HRE recommendation section indicates the Property’s detached garage/cottage and landscape are not eligible for local listing.
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154
DISCUSSION
Page & Turnbull concurs with the 2025 HRE recommendation that the house be removed from the Los Altos Historic Resource Inventory. However, Page & Turnbull clarifies the reasoning as to why it should be removed from the local inventory. The 2011 State of California Department of Parks & Recreation (DPR) 523A and 523B forms, dated June 8, 2011 and prepared by Circa found the 1929 house at 81 Pepper Drive to be, “a good representative example of its style” with a “good degree of integrity of location, workmanship, feeling, design and materials,” and “therefore…eligible for listing on the Los Altos Historic Resources Inventory.”
Page & Turnbull does not concur with the 2011 Circa assessment that the house is a good example of its style. In other words, the house has not demonstrably lost integrity and/or historic significance since the prior (2011) finding of eligibility as stated in the 2025 HRE. Rather, although the Property, inclusive of the 1929 house and ca. 1929 garage/cottage meets the local Criterion A as age eligible, and the house meets local Criterion B as it retains integrity relative to its 1929 date of construction, type, and architectural style, it does not meet local Criterion C as a historically significant resource.
Therefore, 81 Pepper Drive is ineligible for inclusion on the Los Altos Historic Resource Inventory.
Bibliography
The 2025 Historic Resource Evaluation provides a bibliography which is the list of the sources used and referred to within and to prepare the evaluation. This bibliography meets industry standards.
Appendix
The appendix of the 2025 Historic Resource Evaluation provides the California Department of Parks and Recreation (DPR) Form - Primary Record and Continuation Sheets for the property. The information within the forms appears to provide the physical description of the property, photographs and an evaluation like that provided in the 2025 HRE. Page & Turnbull notes the DPR Form includes, however, an aerial image of the property and although not explicitly demarcated, the house and its ancillary component (garage/cottage), are legible. This type of image was lacking in the remainder of the document as previously discussed.
CONCLUSION
At the request of the City of Los Altos Community Development Department, Page & Turnbull has reviewed the 2025 Historic Resource Evaluation for 81 Pepper Drive (APN 170-41-007), Los Altos prepared by Evans & De Shazo, Inc. updated April 21, 2025. Page & Turnbull reviewed the 2025 HRE and other related materials and conducted a field survey and online research. Page & Turnbull has identified several areas for potential improvement of the 2025 HRE. However, Page & Turnbull does
81 Pepper Drive, Los Altos HRE - Peer Review [25162]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 not recommend that the 2025 HRE need be revised for the City of Los Altos to make a finding. With the combined contents of previous evaluations and Page & Turnbull’s additional research and field survey, Page & Turnbull concurs with the finding of the 2025 Historic Resource Evaluation that the property does not appear eligible under any of the California Register criteria, nor does it meet the local Criteria for inclusion on the Los Altos Historic Resource Inventory.
170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 We imagine change in historic and contemporary environments to cultivate thriving, sustainable, and resilient communities.
MEMORANDUM
DATE December 24, 2025 PROJECT
NUMBER
25162.01
TO Brittany Whitehill, AICP, Senior
Planner
PROJECT 81 Pepper Drive, Los Altos
OF City of Los Altos FROM Stacy Kozakavich, Project Manager, Page & Turnbull; and
Jen Hembree, Cultural Resource
Planner, Page & Turnbull
CC Christina Dikas Brobst, AICP,
Principal
VIA Email
REGARDING Appeal Response Memorandum
Introduction
Page & Turnbull prepared this memorandum at the request of the City of Los Altos (City) in response to an appeal of the Los Altos Historical Commission’s October 27, 2025 decision to remove the property at 81 Pepper Drive (APN 170-41-007) from the Los Altos Historic Resources Inventory (HRI).
Page & Turnbull previously provided a Peer Review and independent assessment to the City of the Historic Resource Evaluation prepared in 2025 by Evans & DeShazo, Inc. (2025 HRE), which found that the property was ineligible for listing at the state or local level, and recommended its removal from the HRI. Our Peer Review Memorandum, dated June 16, 2025, concurred with this overall finding. The City has requested our comment on portions of the Appeal, filed on November 7, 2025 (“Appeal”), which are related to the eligibility of the property for listing at the local level. At the request of the City, we have also provided a written response to an email sent to Page & Turnbull by one of the appellants on November 18, 2025.
Response to Appeal
The following paragraphs provide Page & Turnbull’s response to relevant statements made in the November 27, 2025 Appeal, grouped by theme or topic.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Scope of Services
The Appeal states that City “Staff defined the Page & Turnbull report as both a peer review and a Historic Resource Evaluation (HRE) or designation assessment. The report, however, is only a peer review.” The Appeal goes on to state that, “Without a complete HRE and a separate action by the Historical Commission to determine whether a property is eligible for listing,” Page & Turnbull cannot make conclusions about the eligibility of the property.
Page & Turnbull acknowledges that the scope of services performed for the City is defined as a Peer Review Memorandum. A Peer Review Memorandum, in this instance, is intended to address the technical adequacy of an eligibility evaluation and, if necessary, to provide additional information needed by the City in making a determination regarding a property’s significance. The scope of services agreed upon with the City specified that Page & Turnbull include independent analysis regarding the property’s eligibility. The executed agreement between the City and Page & Turnbull established that the scope of services to be performed would consist of, “Peer review of previous reports and independent analysis [emphasis added] to determine whether the property located at 81 Pepper Drive meets the criteria for local listing on the HRI (Los Altos Municipal Code Chapter 12.44). [And] Services will include, but not be limited to, the items noted in the scope of work attached hereto and incorporated herein as Exhibit A.”1 The referenced Exhibit A reiterates that Page & Turnbull would prepare a Peer Review Memorandum which would include our “professional opinion regarding eligibility.”2 As such, to complete the Peer Review Memorandum as outlined in our scope of services, Page & Turnbull performed additional archival research to fill gaps in the historic context presented by previous documentation and provided our professional opinion regarding the property’s eligibility for listing in the Los Altos Register of Historic Resources. As noted in the Peer Review Memorandum, “[w]ith the combined contents of previous evaluations and Page & Turnbull’s additional research and field survey,” the City had been provided with sufficient information and analysis to make a determination regarding the property’s eligibility for continued listing on the HRI.
Eligibility Evaluations
The Appeal states that, “The standard for removal of an HRI listing is ‘loss of integrity and/or historic significance,’ not a reassessment of prior recognized importance that determined the HRI listing. The presumption is that the property has been and is historically significant, being treated officially as such since 2008.”
Page & Turnbull acknowledges that according to Los Altos Municipal Code 12.44.090 - Termination of designation, “The only legitimate reason for terminating the designation of a historic resource or 1 Professional Services Agreement between City of Los Altos and Page & Turnbull, executed on May 13, 2025. 2 Exhibit A, Professional Services Agreement between City of Los Altos and Page & Turnbull, executed on May 13, 2025.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 historic landmark is when clear evidence is presented that shows the resource no longer meets the criteria of Section 12.44 .040 due to loss of integrity and/or historic significance.” However, historic preservation inventories are always works in progress.
Per the California Office Historic Preservation’s Instructions for Recording Historic Resources, As a planning tool, it is important that information about historical resources is regularly updated to ensure its accuracy. Updates may amplify or correct information about a resource, or simply confirm that the existing record remains accurate at the time of a subsequent field examination. The documentation for a historical resource should be updated under the following conditions: When it is reevaluated; When changes occur to the resource or its setting; When erroneous information needs correcting; and/or When additional information is necessary for planning decisions.3
The California Office of Historic Preservation Technical Bulletin 8 in its discussion of California Historic Resource Status Codes, which are typically included on DPR 523 forms, furthers that users of the California Historic Resource Status Codes,
should keep in mind that the status codes are broad indicators which, in most cases, serve as a starting place for further consideration and evaluations. Because the assigned status code reflects an opinion or action taken at a specific point in time, the assigned status code may not accurately reflect the resource’s eligibility for the National Register, California Register, or local listing or designation at some later time.4
Page & Turnbull cannot comment on City’ specific policies for updating or adding information to documentation of existing Los Altos historic resources or historic landmarks. However, it is an established best practice to update or add information about historic resources on a periodic basis.
While in some cases a property previously found ineligible for designation may later be found eligible by evaluators, in other cases a property which is found eligible may later, with further consideration of its context and merits, be found ineligible for designation. This reconsideration may find that in the period between evaluations a property has been altered to the degree that it can no 3 Office of Historic Preservation, “Instructions for Recording Historic Resources,” March,1995, p. 23 electronic resource at:
https://ohp.parks.ca.gov/pages/1054/files/manual95.pdf. 4 Office of Historic Preservation, “Technical Assistance Bulletin 8 - User’s Guide to the California Historical Resource Status Codes & Historic Resources Inventory Directory,” November, 2004, p. 5 electronic resource at:
https://ohp.parks.ca.gov/pages/1069/files/tab8.pdf.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 longer convey its significance. This situation would meet the Los Altos Municipal Code condition that designation may be terminated in response to a “loss of integrity.” The Municipal Code also provides the possibility of termination of designation due to loss of “historic significance.” Significance is an inherent characteristic; a property has significance or it does not, and an original architectural design or an established association with a historic event cannot be “lost.” This phrase in Los Altos’ Municipal Code must therefore be interpreted to mean that, due to research and evaluation subsequent to the initial finding of significance, the preponderance of evidence demonstrates that a resource is not historically significant or eligible for listing.
Local Significance Evaluation
The Appeal states that the 2025 HRE and the Page & Turnbull Peer Review Memorandum analyses lack discussion of the property in relation to the Los Altos Historic Resource Inventory Section II titled, “Los Altos: The Influence of Transportation on Growth and Development and in the National Register Bulletin (National Park Service, Department of Interior),” and states that the property reflects early "’railroad suburban’ development in the inter-war/Great Depression period when a growing middle class sought homes that symbolized stability, simplicity and tradition.” The Los Altos Historic Resource Inventory Section II titled, “Los Altos: The Influence of Transportation on Growth and Development (“Section II”) describes the establishment and growth of the area now incorporated as the city of Los Altos and indicates that both the establishment of a railroad and subsequent mass production of the automobile contributed to the town’s growth. In particular, Section II states that the Los Altos Train Station is a “symbol of the town’s very existence.”5 Section II illustrates that, as occurred in many other towns and cities in the United States during the late 19th and early 20th centuries, a transportation official privately purchased large tracts of undeveloped land and then subdivided the land after the development of a transit line. In Los Altos, Southern Pacific railroad president, Paul Shoup (and his brother) bought a right-of-way from Palo Alto through Los Altos to run a connecting line through Los Gatos and points south. In 1907, his Altos Land Company as well as the University Land Company were incorporated. Both companies had as their objective the layout and subsequent sale of lots in what would be named the town of Los Altos. The train depot was initially a boxcar along the tracks, until 1913, when the Architectural Bureau of Southern Pacific completed a permanent depot at 288 1st Street. Once regular passenger rail service to the town was initiated in 1908, the land companies were able to attract more residents for purposes of establishing homes.6
5 The City of Los Altos and Circa: Historic Property Development, The City of Los Altos Historic Resources Inventory (Los Altos, October 2012), Section II – pp. 11-11. 6 The City of Los Altos Historic Resources Inventory, Section II – pp. II-14 – II-15.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Page & Turnbull observes that the residence at 81 Pepper Drive was constructed in relative geographic proximity to the Los Altos rail station (approximately 0.3 miles as determined by Google Maps). However, its construction occurred in the year 1929, over two decades or 22 years after the establishment of a rail station in Los Altos. The construction of the residence therefore does not appear to be directly associated with the establishment of a rail line, passenger rail service or general rail transportation in Los Altos. In fact, its construction date occurred as passenger rail service was falling out of both national and local favor. According to Section II, less than a decade after the residence’s construction, in 1935, the interurban Peninsular Railway disincorporated. 7 The
Peninsular Railway was the electrified rail passenger service or suburban streetcar service formally incorporated in 1909 and available between San José and Palo Alto including a stop at the Los Altos rail station. Earlier in 1930, in fact the Peninsular Railway had already eliminated through-service to Palo Alto north of Mayfield (present-day California Street area in Palo Alto); in 1933, the company made plans to substitute buses for the streetcars on all interurban routes and in 1934 it ceased the Mayfield line entirely.8 The house constructed at 81 Pepper Drive in Los Altos in 1929 thus does not appear to be associated with streetcar suburban development in Los Altos.
The residence at 81 Pepper Drive therefore does not appear to reflect “early ‘railroad suburban’ development in the inter-war/Great Depression period.” In Page & Turnbull’s understanding of the history of Los Altos outlined in Los Altos Historic Resource Inventory Section II, the early railroad suburban era in Los Altos is more appropriately described as the initial years following the establishment of the rail service and depot in the town, that is 1907/08 until about 1920. According to the Section II, “The 1920s saw the growth of the automobile suburb.”9 The subject property’s association with the growth of automobile use in Los Altos is discussed below.
Page & Turnbull notes that Section II indicates that, per Eastman’s “History of Los Altos” (in author, Joe Salameda’s 1981 publication, “Memories of Los Altos”), Los Altos had --by July of 1911-- “boasted some fifty houses…” These earlier houses, those built in the first decade of the 20th century, would therefore be more likely associated with the early railroad development of the town and likely better representatives of that era. Examples include:
• J. Gilbert Smith House (now the Los Altos History Museum) at 51 S San Antonio Road, half a mile from the rail station. This Craftsman-style farmhouse was constructed between 1901- 1905 and is a Los Altos Landmark.
7 The City of Los Altos Historic Resources Inventory , Section II – pp. 11-17. 8 Charles S. McCaleb, Tracks, Tires, and Wires. (Glendale, California: Interurban Press, 1981), pp. 95-97. 9 The City of Los Altos Historic Resources Inventory , Section II – pp. II-17.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 • The residence at 42 Los Altos Avenue, 0.4 miles north of the rail station, was constructed in 1910.10
The Appeal states that “81 Pepper Drive is the first house built in the first near-town subdivision of Los Altos.”
As outlined in the 2025 HRE, the property addressed at 81 Pepper Drive is located within what was initially M.O. Wight’s 20-acre property within what was initially the L.S. Clark Subdivision. The land was subsequently subdivided further and became part of the Adams Subdivision. A 1926 map of the Adams Subdivision indicates it spanned approximately between San Antonio Road at the west to Eleanor Avenue at the east and between the south side of Hawthorne Avenue at the north southward through the south side of Marvin Avenue. Several residences predate the property at 81 Pepper Drive and were constructed within these bounds prior to 1929. Examples include (but are not limited to):
The residence located at 55 Pepper Drive was constructed in 1906, a few parcels west of today’s 81 Pepper Drive. Known as the Adam House, it is designated Los Altos Landmark. • The residence located at 236 Eleanor Drive was constructed in 1919, northeast of today’s 81 Pepper Drive. Known as the Morris House, it is listed in the Los Altos Historic Resource Inventory.11
• The residence at 96 Hawthorne Avenue located directly north of today’s 81 Pepper Drive was constructed in 1920.
Other properties located outside of the bounds of the Adams Subdivision, but in proximity to 81 Pepper Drive and constructed prior to 1929 include:
• The residence at 41 Hawthorne Avenue, constructed in 1925 and in the Los Altos Historic Resource Inventory.
• The residence at 109 Hawthorne Avenue, constructed in 1920 and in the Los Altos Historic Resource Inventory.
• The residence at 151 Hawthorne Avenue, constructed in 1920 and in the Los Altos Historic Resource Inventory.
10 State of California Office of Historic Preservation Built Environment Resources Directory for Santa Clara County, September 23, 2022, electronic resource at: https://ohp.parks.ca.gov/pages/1068/files/Santa%20Clara.csv 11 Circa: Historic Property Development. DPR 523 Primary Record for 236 Eleanor Avenue, 2011, electronic resource at:
https://mccmeetingspublic.blob.core.usgovcloudapi.net/losaltosca-meet-56429ae0ef5a49619f7761b53dc34e06/ITEMAttachment-001-06bf557386ae4cafbb962e02efaccc7b.pdf. Note that online market listings indicate the property was constructed slightly earlier in 1914.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 • The residence at 165 Hawthorne Avenue, constructed in 192512 The residence at 81 Pepper Drive therefore does not appear to have been the first house built in the first near-town subdivision of Los Altos. Early examples dating from five to twenty years prior to the construction of 81 Pepper Drive exist not only within the Adams Subdivision, but also within the general vicinity, some of which are locally designated landmarks or on the historic resource inventory.
The Appeal states that 81 Pepper Drive’s “small, rectangular lot and the burgeoning automobile era favored a 1 1/2 story structure with a side-yard detached garage; 81 Pepper Drive is the only era-specific Colonial Revival with an original detached garage in Los Altos. With most original details intact, the house perfectly represents the small-town ideal of 1920-40, especially with respect to transportation trends.”
Page & Turnbull acknowledges that the primary residence is a Colonial Revival “Cape Cod cottage” subtype. Page & Turnbull also acknowledges that National Register Bulletin 46: Historic Residential Suburbs, which is referred to by the appellants in the Appeal and November 18 email, recognizes the impact of automobile travel on suburban development and pays particular attention to the introduction and proliferation of garages.13 As further noted in the Bulletin 46, “[s]helter for the automobile became an increasingly important consideration after 1900.” 14 The presence of a detached garage, although generally associated with the national historic trend of providing detached garages as part of residential construction, does not appear to be an important or sole determinant of a property’s historic significance, regardless of the architectural style of the associated dwelling itself. The garage became important beginning as early as the year 1900 per the National Register Bulletin 46. Locally, detached garages appear within the 1926 Sanborn Fire Insurance Maps for Los Altos (the earliest date Sanborn maps are available). Indicated by the letter ‘A’ (for automobile) on these Sanborn Maps, a review of the 1926 Los Altos Sheet No. 2 shows that at least four dwellings on Third Street between Main and Edith streets featured detached garages set back towards the rear of their properties. At least eleven dwellings along Orange and University avenues also featured detached garages at their rears as evidenced by the 1926 Los Altos Sheet No.
4. 12 Dates of construction provided in California Office of Historic Preservation Built Environment Resource Directory for Santa Clara County. 13 Best Practices Review: Garages and Outbuildings, dated January 2023 electronic resource at:
https://www.nps.gov/subjects/nationalregister/upload/BPR_garages-and-outbuildings-2022-01-06.pdf. 14 National Register Bulletin 46: Historic Residential Suburbs, p. 56 electronic resource at:
https://www.nps.gov/subjects/nationalregister/upload/NRB46_Suburbs_part1_508.pdf.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 Further, the Peer Review Memorandum clarified that the existing detached garage dates to ca. 1929 and the house dates definitively to 1929. This clarification is based on a 1929 newspaper article that describes the original owners/occupants (the Van Epps) as “occupying temporary quarters on the property,” while their new home was under construction.15 Initially, therefore, the ancillary building on the property appears to have functioned as a cottage and was likely subsequently converted for use as a garage.
Regardless of its initial intended function, as stated in National Register Bulletin 15, “mere association with historic events or trends is not enough, in itself to qualify under [National Register] Criterion A:
the property’s specific association must be considered important as well [to the trend].”16 The evolution of the automobile which necessitated the construction and prevalence of detached garages was already well-established and not uncommon in Los Altos prior to the construction of 81 Pepper Drive in 1929. The presence of a garage at 81 Pepper Drive is not a specific and important association with the nationwide trend of increasing automobile use in Los Altos, California, or the United States.
The Appeal states that, “At the time, the ‘Homebuilder’ becomes a profession with the likes of original homeowner Harry VanEpps.”
According to the 1930 federal census, Van Epps was a carpenter in the “house building” industry. No documentary evidence was found to verify whether Van Epps constructed the primary residence at 81 Pepper Drive. Moreover, the profession of a property owner, such as Harry VanEpps’ profession of carpenter does not immediately elevate a property to a level of significance necessary for listing in a local, state or federal register. National Register Criterion B: Person (equivalent to State Criterion 2) indicates a property may be eligible if it is associated with the lives of persons significant in our past.
However, according to the National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, “A property is not eligible if its only justification for significance is that it was owned or used by a person who is a member of an identifiable profession, class, or ethnic group. It must be shown that the person gained importance within his or her profession or group.”17 Research did not identify that Van Epps gained importance within his carpentry / house-building profession in Los Altos or elsewhere. Research did not identify that any family member having an association with the 15 The Peninsula Times Tribune, “To Occupy New Home,” July 15, 1929. 16 National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, p. 12, electronic resource at https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf. 17 National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, p. 15, electronic resource at https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 occupancy or ownership of 81 Pepper Drive was significant to the history of Los Altos, the state, or nation.
The Appeal states that, “With a symmetrical facade, detached garage and proximity to town and the train station, 81 Pepper Drive is tied to national patterns of residential architecture and provides a prime and unique example of the Los Altos' transition from agricultural lands to middle class suburban neighborhoods.”
As noted above, per National Register Bulletin 15, “mere association with historic events or trends is not enough, in and of itself, to qualify under Criterion A: the property’s specific association must be considered important as well [to the event or trend].”18 A property’s importance to (not just representation of) the trend or pattern therefore must be clearly evident. For example, although the property at 81 Pepper Drives appears to have been generally associated with the national trend of providing detached garages at dwellings during the rise of the automobile as the preferred transportation method in the early 20th century, the associated detached garage at 81 Pepper Drive appears to have initially functioned as a cottage, and furthermore, was constructed in 1929, near the end of the 1920s decade of growth of the automobile suburb as per Section II. Similarly, the transition from agricultural land to residential neighborhoods was a nationwide trend during the early decades of the twentieth century during which 81 Pepper Drive was constructed. However, the property is one of many examples of residential properties built in the Bay Area, California, and Nationwide during this time. Research has not provided evidence that the property was individually important to the initiation and spread of this trend in Los Altos. Other residences within what became the Adams Subdivision predate the property. Other residences outside of the bounds of the Adams Subdivision, but in proximity to 81 Pepper Drive predate the property. Other dwellings within the vicinity of downtown included detached garages prior to or by 1926 as per Sanborn maps. The property therefore does not appear to be a prime, unique, or influential example of the Los Altos transition from agricultural lands to middle class suburban neighborhoods.
The Appeal states that the primary residence, a “high integrity Colonial Revival ‘Cape Cod’ subtype aka ‘Colonial Bungalow’ of 1920s Los Altos” was designed in a style that “parallels popular Tudor, Dutch and Spanish Colonials, but speaks to a desire for a more American vernacular free from Victorian ornamentation,” and that “Modest architectural structures are never automatically insignificant because of their modesty; both professional reports rely on deficiencies in grandeur.
In fact, 81 Pepper Drive is significant because of its modesty.” 18 National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, p. 12, electronic resource at https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 When evaluating a property for eligibility for national, state or local designation under criteria related to type, period, or method of construction -- that is, architecture, it is best practice to utilize an objective methodology. First, a particular type or style must be demonstrably important within its historic context. Simply stated, as much as grandeur is not a requirement for a residential property to be found historically significant, so too integrity alone as an example of a common style or type is not sufficient for a property to rise to the level of significance required for designation. That style or type must itself be significant within the context of a property’s location and period of construction.
Then, the essential physical features – the character-defining features – that enable the property to convey its historic identity related to type, period, or method of construction must be evident. These distinctive character-defining features are the physical traits that commonly recur in property types and/or architectural styles. To be considered an excellent example and eligible under the criteria related to Architecture, a property must clearly contain enough of these characteristics to be considered a true representative of a particular type, period, or method of construction, and these features must also retain a sufficient degree of integrity. Evidencing the essential or characterdefining features ensures that properties are evaluated objectively for their architecture.
Architectural historian’s Virginia McAlester’s A Field Guide to American Houses, most recently updated in 2023, is considered the definitive guide to residential architecture in America. A Field Guide to American Houses presents a list of character-defining physical features that must be present for a building to be a true representative of and significant as a particular architectural style. As outlined in McAlester’s guide and in the 2025 HRE, the character-defining features of the Colonial Revival architectural style are:
1. “Symmetry in façade – although 10% of Colonial Revival were asymmetrical.
2. Hipped or gabled roofs with boxed eaves.
3. Fanlights and/or sidelights around main door.
4. Double-hung sash windows, often set in pairs.
5. Clapboard and brick exterior cladding.
6. Classical detailing (sometimes exaggerated), including pediments, columns or pilasters leading to elaborate entries.”19
As further stated in A Field Guide to American Houses, the One-Story Subtype or ‘Cape Cod cottage,’ which the property at 81 Pepper Drive most closely resembles, “are loosely patterned after early wooden Cape Cod folk houses of eastern Massachusetts, usually with the addition of Georgian or Federal-inspired doorways [emphasis added]. These were built throughout the Colonial Revival era 19 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023).
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 but were particularly common in the 1940s…”20 [and] “The Cape Cod is the most common form of one-story Colonial Revival house. As a form, it originated in the early 18th century and continued with few changes through the 1950s.”21
The property at 81 Pepper Drive lacks the pediments, columns or pilasters leading to elaborate entries of the overarching Colonial Revival style and thus, also lacks the usually added Georgian or Federal-inspired doorways typical of the Cape Cod cottage subtype. The extant residence instead has a non-original door set within a flat surround with sidelights only and a contemporary arbor trellis.
Further, as instructed by the California Office of Historic Preservation when recording historical resources, it is also important to “compare the resource with others that belong to the same property type and relate to the same historic context” because “it will help establish the significance of the resource,” or will help provide a clear rationale to support an ineligible finding.22 The Los Altos Landmark properties at 1448 Fowler Lane and 1570 Kensington Circle both predate the property at 81 Pepper Drive and both fully express the Colonial Revival style, inclusive of elaborate entries. The property at 81 Pepper Drive is not the best extant early-20th century example of the Colonial Revival style in Los Altos. Other, better examples are extant and designated landmarks.
Modesty of a property in and of itself does not preclude that a particular property might be significant as an example of a style or type. Nonetheless, for potential resources that are common or vernacular, such as the Cape Cod cottage subtype and the property at 81 Pepper Drive, the question of what makes one Cape Cod Cottage, or the property at 81 Pepper Drive among many examples of Cape Cod cottages, significant, must be answered.23 National Register guidance indicates that for a common or vernacular property to be eligible as a specimen of its type or period of construction, “it must be an important example (within its context) of building practices of a particular time in history.” The property at 81 Pepper Drive does not appear to be an important example of a modest or vernacular Cape Cod cottage during the early 20th century or 1920s in Los Altos.
National Register guidance also states that, that “for properties that represent the variation, evolution, or transition of construction types, it must be demonstrated that the variation, etc., was an important phase of the architectural development of the area or community in that it had an 20 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), 412. 21 Virginia Savage McAlester, A Field Guide to American Houses (Revised Edition. New York: Knopf, 2013, reprinted 2023), 427. 22 https://ohp.parks.ca.gov/pages/1054/files/manual95.pdf. 23 National Register of Historic Places, “Best Practices Review: Evaluating Common Resources,” dated July 2023, electronic resource at: https://www.nps.gov/subjects/nationalregister/upload/BPR_common-resources-2023-07-27-REV.pdf.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 impact as evidenced by later buildings.”24 The property at 81 Pepper Drive does not appear to represent a variation or evolution or transition of construction types in Los Altos that resulted in a new phase of architectural development in the area.
Response to Email, dated November 18, 2025
On November 17, 2025, one of the signatories to the Appeal spoke with Page & Turnbull staff regarding the Peer Review Memorandum. The phone call was followed by an email from the signatory to Page & Turnbull Principal, Christina Dikas Brobst and dated November 18, 2025. Page & Turnbull provides the following clarifications in response to the email.
The email states that the previous conversation communicated “an assumption[…] that a Peer Review has a lesser standard of thoroughness than a full HRE.” In Page & Turnbull’s practice, a peer review does not have a lesser standard of thoroughness than a full Historic Resource Evaluation. As stated above, while preparing the Peer Review Memorandum, Page & Turnbull performed additional archival research, as necessary, to fill gaps in the historic context presented by previous documentation and, for example, was able to clarify certain dates of construction. However, a peer review need not be redundant, or repeat accurate information or relevant context already provided for the same property in a previous document. With the combined contents of previous evaluations and Page & Turnbull’s additional research and field survey, Page & Turnbull recommended that the 2025 Historic Resource Evaluation need not be revised.
The email states that Page & Turnbull’s “method of evaluation was only “in the context of the state of California” and not within the context of local history.
This appears to be a misunderstanding of the word “context” in that particular statement. To our recollection, the context referred to in this part of the conversation was the breadth of comparative experience from which Page & Turnbull’s architectural historians approach an evaluation, whether for significance at the national, state, or local level. Page & Turnbull was established in 1973 as Charles Hall Page & Associates to provide architectural and conservation services for historic buildings, resources, and civic areas within cites and towns across the state. The company was one of the first architecture firms in California to dedicate its practice to historic preservation and is among the longest practicing such firms in the country. Offices are located in San Francisco, San José, Los Angeles, and Sacramento, and staff includes planners, architectural historians, licensed 24 National Register of Historic Places, “Best Practices Review: Evaluating Common Resources,” dated July 2023, electronic resource at: https://www.nps.gov/subjects/nationalregister/upload/BPR_common-resources-2023-07-27-REV.pdf.
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 architects, designers, and conservators. All of Page & Turnbull’s professional staff members meet or exceed the Secretary of the Interior’s Professional Qualifications Standards as published in the Code of Federal Regulations, 36 CFR Part 61. The number of evaluations of age-eligible buildings within the firm’s body of knowledge is extensive and serves as a valuable resource to staff, as do leadership and fellow staff, allowing Page & Turnbull to evaluate properties as objectively as possible and within their appropriate historic contexts.
The email states that Page & Turnbull’s peer review memorandum “is absent recognition of Los Altos HRI Historic Contexts and of regional, state and national trends in architecture that are clearly spelled out in National Register data on Historic Residential Suburbs. The report also does not provide context for 81 Pepper Drive’s relevance to the entirety of the Los Altos HRI.” With respect to evaluation at the local level and according to local contexts, as defined by the California Office of Historic Preservation,
Historic context statements are intended to provide an analytical framework for identifying and evaluating resources by providing, focusing on and concisely explaining what aspects of geography, history and culture significantly shaped the physical development of a community or region’s land use patterns and built environment over time, what important property types were associated with those developments, why they are important, and what characteristics they need to have to be considered an important representation of their type and context.25 Where locally specific and/or geographically relevant historic context has been developed, such as the context discussion in the Los Altos Historic Resource Inventory, evaluators should prioritize these in providing a framework within which to understand a property’s significance. In communities and locales where context statements have not been prepared, broad, nationwide contexts such as National Register Bulletin 46: Historic Residential Suburbs can be useful. However, in these cases, it is important for evaluations to demonstrate the local significance and expression of the themes discussed in works which may have been compiled with a broader geographic view.
In any individual evaluation, a historic preservation professional will select the appropriate and relevant themes within which to assess a property’s significance. Evaluations need not address and demonstrate significance (or lack thereof) against all themes in the entirety of a city’s historic context statement. Los Altos Historic Resource Inventory Section II outlines four specific Los Altos contexts:
Context 1: Prehistory; Context 2: Agriculture 1850 to 1940; Context 3: Residential Architecture 1907 25 https://ohp.parks.ca.gov/pages/1054/files/WritingHistoricContexts.pdf
Appeal Response Memorandum [25162.01]
PAGE & TURNBULL 170 MAIDEN LANE, 5TH FLOOR SAN FRANCISCO, CALIFORNIA 94108 TEL 415-362-5154 to 1940; and Context 4: Institutional Development 1907 to 1940. Additional discussion is provided in two subsequent sections, “Los Altos: The Influence of Transportation on Growth and Development” and “Profile of Los Altos: 1907 to 1930.”
Context 3 outlines the important property types associated with the residential architecture of Los Altos, including architectural styles. It is within this context that the property at 81 Pepper Drive is most appropriately considered. As all buildings are a product of their time and the trends of that period, when evaluating properties for significance it is necessary to determine whether a property is associated with the period or the trend in any important way.26 Page & Turnbull’s evaluation of 81 Pepper Drive within the outlined Context 3 found that, although the property is associated with the general trend of Los Altos’ growth in the 1920s, the property is not specifically important to the initiation and development of this trend and thus does not convey significance for its association with that particular growth period.
Taken together, the 2025 HRE, prior documentation, and additional research performed by Page & Turnbull do not suggest that 81 Pepper Drive is associated in any important way to events, persons, architecture, or archaeology at the local, state, or national level. 26 National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, p. 12, electronic resource at https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf.
City Council Staff Report
Meeting Date: January 27, 2026
Prepared By: Melissa Thurman
Approved By: Gabe Engeland
Subject: City Council Discussion - Vacancy
COUNCIL PRIORITY AREA
General Government
RECOMMENDATION
Discuss and provide direction on City Council vacancy
ENVIRONMENTAL IMPACT
Not applicable.
FISCAL IMPACT
Based on a cost estimate provided by the Santa Clara County Registrar of Voters, placing the vacancy on the June 2, 2026 election ballot is estimated to cost the City of Los Altos $96,393.
Actual costs may vary and will be determined upon final billing.
As of the preparation of this report, staff has not received a cost estimate from the Santa Clara County Registrar of Voters for the November 3, 2026 consolidated election. Actual costs will be determined upon receipt of a formal estimate and final billing.
PREVIOUS COUNCIL CONSIDERATION
Not applicable.
BACKGROUND
During the regular meeting of January 13, 2026, Vice Mayor Neysa Fligor resigned from the Los Altos City Council following her election to the office of Santa Clara County Assessor.
ANALYSIS
Not applicable.
DISCUSSION
Pursuant to Government Code section 36512, when a vacancy occurs on a City Council, the vacancy must be filled either by appointment or by special election.
If the City Council elects to fill the vacancy by appointment, the appointment must be made within 60 days of the occurrence of the vacancy. As the vacancy occurred on January 13, 2026,
the City Council must make a final appointment no later than March 14, 2026.
If the City Council elects to fill the vacancy by special election, the procedures and timelines set forth in the California Elections Code apply. The next available statewide election dates for purposes of filling the vacancy are June 2, 2026 and November 3, 2026, as reflected on the Santa Clara County Registrar of Voters’ Established Election Dates webpage: Santa Clara County ROV - Established Election Dates
The City of Los Altos conducts its municipal elections in consolidation with the Santa Clara County Registrar of Voters. As a result, statutory deadlines must be met in order to place a City Council vacancy on an election ballot. To place the vacancy on the June 2, 2026 election ballot, the City Council must adopt a resolution calling for the election no later than January 28, 2026.
This deadline is reflected in the Santa Clara County Registrar of Voters’ June 2, 2026 Primary Election Calendar: Santa Clara County ROV - June 2, 2026 Primary Election Calendar If the City Council adopts a resolution calling for an election on January 29, 2026, or later, the vacancy would instead be filled at the next regularly scheduled election on Tuesday, November 3, 2026. In that event, the vacant Council seat would remain unfilled until the election is held and the results are certified.
The term of the vacant Council seat is scheduled to expire in November 2026 and would otherwise be subject to election at the November 3, 2026 general municipal election. If the City Council calls a special election for June 2, 2026, the candidate elected to fill the vacancy would assume office upon certification of the election results and serve for the remainder of the term.
ATTACHMENTS
None
City of Los Altos 2026 Tentative Council Agenda Calendar All items and dates are tentative and subject to change unless a specific date has been noticed for a legally required Public Hearing.
Items may be added or removed from the shown date at any time and for any reason prior to the publication of the agenda.
February 10, 2026 – 7:00 p.m.
DISCUSSION ITEMS:
• Mid-Year Budget Adjustments
• Council Vacancy Discussion
• JVAC Composition and Recommendation from Committee
• Number of Commissioners on Commissions
• Review of Council Norms
February 24, 2026
Study Session – 5:00 p.m. – Downtown Park
Special Meeting – 6:00 p.m. Joint Meetings with Commissions Regular Meeting – 7:00 p.m.
CONSENT:
• Adoption of Council Norms
PUBLIC HEARINGS:
• Weed Abatement Appeals
• 4846 El Camino Real – Modification to Below-Market-Rate Unit Mix DISCUSSION ITEMS:
• Council Priority Setting and Future Agenda Item Review • Council Vacancy Discussion
The remaining 2026 City Council agenda calendar items are pending and will be published at a later date.
PROGRAM SUB PROJECT INITIATION DATE HEU COMPLETION DATE STATUS Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs).
Budget & Hire Planning
Technician December 31, 2022 COMPLETED
Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs).
Amend ADU Ordinance
based upon HCD's letter 6 months or less COMPLETED
Program 6.G: Housing mobility
Allow more than one
JADU (at least two per
site)
with ADU Ordinance
Update COMPLETED
Program 3.H: Amend design review process and
requirements.
Eliminate 3rd Party
Architectural Review February 28, 2023 COMPLETED
Program 3.H: Amend design review process and
requirements.
Dismiss Design Review
Commission February 28, 2023 COMPLETED
Program 3.L: Eliminate the requirement of story poles. March 31, 2023 COMPLETED Program 2.E: Conduct annual ADU rental income surveys.
Budget & Hire Housing
Program 4.J: Facilitate alternate modes of transportation for Manager March 31, 2023 COMPLETED residents.
Adopt VMT Policy &
Transportation Demand June 30, 2023 COMPLETED
Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs).
RFP-Permit Ready ADU
Plans July 31, 2023 COMPLETED
Program 1.H: Facilitate housing on City-owned sites. Financial Analysis July 1, 2023 December 31, 2023 COMPLETED Program 3.D: Evaluate and adjust impact fees. August 1, 2023 December 31, 2024 COMPLETED Program 1.H: Facilitate housing on City-owned sites. Release RFP December 31, 2023 COMPLETED Program 6.C: Target housing development in highest
resource areas. Initial Outreach September 31, 2023 COMPLETED Program 6.D: Promote Housing Choice (Section 8) rental
assistance program. September 31, 2023 COMPLETED
Program 2.A: Continue to implement and enhance
inclusionary housing requirements. December 31, 2023 ONGOING Program 2.B: Establish an affordable housing in-lieu fee and commercial linkage fee. Housing in-lieu fee. December 31, 2023 COMPLETED Program 2.F: Water and Sewer Service Providers. December 31, 2023 COMPLETED Program 3.B: Modify building height in mixed-use zoning districts. Downtown Districts December 31, 2023 COMPLETED Program 3.E: Ensure that the density bonus ordinance
remains consistent with State law. December 31, 2023 ONGOING
Program 3.H: Amend design review process and
requirements. Code Amendments December 31, 2023 COMPLETED Program 3.K: Standardize multimodal transportation
requirements.
Bicycle Storage and
Charging Regulations December 31, 2023 COMPLETED
Program 3.K: Standardize multimodal transportation
requirements.
Remove CSC Review of
Housing Developments December 31, 2023 COMPLETED
Program 4.C: Allow Low Barrier Navigation Centers
consistent with AB 101. December 31, 2023 COMPLETED
Program 4.D: Allow transitional and supportive housing
consistent with State law. December 31, 2023 COMPLETED
Program 4.E: Allow employee/farmworker housing
consistent with State law. December 31, 2023 COMPLETED
Program 4.F: Reasonably accommodate disabled persons’
housing needs. December 31, 2023 COMPLETED
Program 6.B: Maintain and expand an inventory of affordable housing funding sources. Prepare Inventory. December 31, 2023 COMPLETED Program 6.E: Prepare and distribute anti-displacement
information. December 31, 2023 COMPLETED
Program 1.A: Rezone for RHNA shortfall. January 31, 2024 COMPLETED Program 1.G: Rezone housing sites from previous Housing Elements. January 31, 2024 COMPLETED
Program 3.G: Amend Conditional Use Permits findings
applicable to housing developments. March 31, 2024 COMPLETED Program 3.I: Allow residential care facilities consistent with State law. January 31, 2024 COMPLETED
Program 3.J: Explicitly allow manufactured homes consistent with State law. January 31, 2024 COMPLETED
Program 3.F: Reduce Conditional Use Permit requirement for residential mixed-use and
multi-family. September 31, 2024 COMPLETED
Program 1.B: Facilitate higher density housing in the
Commercial Thoroughfare (CT) District. January 31, 2024 COMPLETED Program 1.C: Allow housing in the Office Administrative (OA) District. January 31, 2024 COMPLETED
Program 1.E: Update the Loyola Corners Specific Plan. January 31, 2024 COMPLETED Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs).
Adopt-Permit Ready ADU
Plans December 31, 2024 COMPLETED
Program 3.A: Prepare a Downtown parking plan and update citywide parking requirements. Downtown Parking Plan December 31, 2024 COMPLETED Program 3.A: Prepare a Downtown parking plan and update citywide parking requirements.
Comprehensive Parking
Ordinance Update December 31, 2024 COMPLETED
Program 3.B: Modify building height in mixed-use zoning districts.
Commercial
Neighborhood (CN)
District December 31, 2024 COMPLETED
Program 3.C: Remove floor-to-area ratio (FAR) restriction at Rancho Shopping Center and
Woodland Plaza. December 31, 2024 COMPLETED
Program 3.M: Modify parking requirements for emergency
shelters consistent with State
law. December 31, 2024 COMPLETED
Program 2.B: Establish an affordable housing in-lieu fee and commercial linkage fee. Commercial linkage fee. December 31, 2025 COMPLETED Program 1.D: Allow housing on certain Public and
Community Facilities District sites and
facilitate housing on religious institution properties. December 31, 2025 IN-PROGRESS Program 6.G: Housing mobility
Allow housing on all
religious sites within the
City December 31, 2025 IN-PROGRESS
Program 1.F: Rezone Village Court parcel. December 31, 2025 COMPLETED Program 4.H: Provide additional density bonuses and
incentives for housing that accommodates special needs
groups. December 31, 2025 IN-PROGRESS
Program 4.I: Allow senior housing with extended care
facilities in multi-family and mixed-use zoning districts. December 31, 2025 IN-PROGRESS Program 1.I: Incentivize Downtown lot consolidation. July 31, 2026 Program 4.G: Assist seniors to maintain and rehabilitate their homes. July 31, 2026 ONGOING
Program 6.C: Target housing development in highest
resource areas. Follow-up Outreach September 31, 2026
Program 1.H: Facilitate housing on City-owned sites. Entitlement Review December 31, 2026 Program 3.N: Modify standards in the R3 zoning districts. December 31, 2026 COMPLETED Program 4.J: Facilitate alternate modes of transportation for residents.
Capital Improvement
Project for above head
pedestrian crossing
signals on San Antonio
Road near Downtown Los
Altos December 31, 2027
Program 5.F: Incentivize the creation of play areas for multifamily housing projects. December 31, 2027 Program 1.K: Participate in regional housing needs planning efforts. Ongoing ONGOING
Program 1.L: General Plan amendments. Ongoing ONGOING
Program 1.M: SB 9 implementation. Ongoing ONGOING
Program 1.N: Facilitate and monitor pipeline housing
projects. Ongoing ONGOING
Program 2.C: Assist in securing funding for affordable
housing projects. Ongoing ONGOING
Program 2.D: Encourage and streamline Accessory Dwelling Units (ADUs). Ongoing ONGOING
Program 2.E: Conduct annual ADU rental income surveys. Annual Survey Annually ONGOING Program 4.A: Support efforts to fund homeless services. Ongoing ONGOING Program 4.B: Continue to participate in local and regional forums for homelessness,
supportive, and transitional housing. Ongoing ONGOING
Program 5.A: Monitor condominium conversions. Ongoing ONGOING Program 5.B: Continue to administer the City’s affordable housing programs. Ongoing ONGOING
Program 5.C: Restrict commercial uses from displacing
residential neighborhoods. Ongoing ONGOING
Program 5.D: Implement voluntary code inspection program. Ongoing ONGOING Program 5.E: Help secure funding for housing rehabilitation and assistance programs. Ongoing ONGOING
Program 6.A: Assist residents with housing discrimination and landlord-tenant
complaints. Ongoing ONGOING
Program 6.B: Maintain and expand an inventory of affordable housing funding sources.
Inform, Evaluate
Apply/Submit Ongoing ONGOING
Program 6.F: Affirmatively market physically accessible units. Ongoing ONGOING Program 7.A: Promote energy and water conservation and
greenhouse gas reduction
through education and awareness campaigns. Ongoing ONGOING Program 7.B: Monitor and implement thresholds and
statutory requirements of climate change legislation. Ongoing ONGOING
DATE: 01/27/2025
TO: COUNCILMEMBERS
FROM: CITYMANAGER’SOFFICE
SUBJECT: COUNCIL Q&A FOR JANUARY 27, 2026 CITY COUNCIL REGULAR
MEETING
Agenda Item 3 (Weed Abatement Program):
• Are there any properties on the list that are repeats from last year? If so, which properties? If there are repeats, what action will the City take with respect to the repeat offenders? Answer: Properties enrolled in the program remain subject to monitoring and therefore on the list for up to three years. If no abatement action is required during that period and compliance is demonstrated through inspections, the property is removed from the program. The 2026 list contains three new properties that were not previously included.
Enforcement under the Weed Abatement Program is administered by the Santa Clara County Consumer and Environmental Protection Agency on behalf of the City. If properties continue to be non-compliant for multiple years, they continue to be abated and the property owner charged for this abatement.
• How will the appeal process be handled? Will appeals come to the Council again or will they be handled at the staff level?
Answer: The appeals will be heard by City Council at a public hearing on February 24, 2026. • How many of the properties that Council granted an appeal to in 2025 are back on the list this year, presumably meaning that they still didn’t abate their weeds or other hazards? Answer: See answer to previous question.
• Last year, Council heard a set of appeals where property owners demonstrated they had responded with appropriate weed abatement. Is there a more streamlined process property owners can follow, to avoid taking their time and Council’s? Answer: Identified properties that provide appropriate weed abatement after being listed but before the appeal hearing will continue to be on the list unless removed at the public hearing. If continued compliance occurs for three years, then they will be removed. Property owners are given the opportunity to meet with inspectors or schedule a follow-up inspection to not be placed on the list and subsequently appeal. It is likely that some property owners will continue to not take the necessary steps to abate the overgrowth until the list is published.
• Are any of the properties on the list repeats from last year? Answer: See answer to previous question.
Agenda Item 4 (Grant and Shoup Park Playgrounds):
• Please provide a copy of the RFP that went out on this item.
Answer: CF01038 RFP Playground Renovations at Grant Park and Shoup Park.pdf • Please describe the public outreach on the design and materials used for the Park improvements.
Answer: As with other equipment replacement projects like this, the public outreach process does not begin until we select a vendor/contractor. Item 4 is to approve entering into an agreement with the recommended vendor/contractor for playground equipment purchase and design that will replace the playground equipment at Grant and Shoup parks. • Will this project improve/replace both playgrounds at Shoup? Answer: Yes. The project will improve and replace both playground areas at Shoup Park, including the tot lot serving children ages 2–5 and the youth playground serving children ages 5–12.
• Please provide copies of the approved plans for each park playground including details about the amenities to be installed in each playground.
Answer: Staff does not have final plans or final amenities listings for these replacements.
Item 4 is to approve entering into an agreement with the recommended vendor/contractor for playground equipment purchase and design that will replace the playground equipment at Grant and Shoup parks. As part of the RFP process, those responded were asked to provide recent examples of their playground designs that are contemporary and representative of their current capabilities and design standards. Staff is asking Council to enter into a contract with the selected vendor/contractor. • Resolution: We can’t live in the past – please update the resolution to indicate that it is to be adopted in the year 2026 (not 2025).
Answer: Thank you for the comment. The resolution will be updated to reflect adoption in the year 2026.
• Can you please provide context on the safety concerns in public comments we’ve received? Answer: The case for Poured-In-Place (PIP) rubber surfacing rests on a critical scientific distinction that the presence of chemicals is not the same as exposure to chemicals.
While community concerns often highlight various substances found in synthetic rubber, the 2024 EPA/CDC/CPSC Federal Research Action Plan confirms that these chemicals, if present, do not lead to significant or elevated exposure. This results in bio-accessibility levels so low that children’s systemic exposure is statistically indistinguishable from that of the general population. The study confirmed this through blood and urine analysis of children after playing on PIP surfaces. In fact, children encounter equal or significantly greater levels of similar chemicals through routine daily contact with household items like cell phones, computers, upholstered furniture, and objects made from recycled plastic bags, as well as through common environmental factors like urban air, dust, and grilled foods. Additionally, studies do not show a difference in cumulative lifetime exposure levels between PIP and natural grass or other natural surfaces; this is largely due to the presence of these chemicals in modern urban and suburban lifestyles.
Beyond chemical analysis, the Consumer Product Safety Commission (CPSC), the primary authority on domestic playground safety, continues to officially list recycled rubber as an appropriate surfacing material in its 2024/2025 Safety Handbook. The CPSC maintains this approval because falls account for nearly 80% of all playground injuries, making the prevention of injuries, including trips, falls, broken bones, or traumatic brain injuries (TBIs) the highest safety priority. The acute risk of a head injury from a fall is considered a much greater threat to child health than the theoretical, low-level cumulative risk of chemical exposure. Unlike loose-fill alternatives like engineered wood fiber, which can decompose, freeze, or be displaced to create dangerous "kick-out" pits, PIP provides a permanent and consistent safety barrier that meets rigorous impact attenuation standards 24/7.
Finally, PIP surfacing is considered the "gold standard" for inclusive play based on the standards and technical guidance of the United States Access Board (USAB), the National Center on Accessibility (NCA), the Americans with Disabilities Act National Network (ADANN), and the American Society for Testing and Materials International (ASTM), because it provides a firm and seamless transition that allows children with mobility devices to play alongside their peers without physical barriers. While naturallooking alternatives are often promoted as healthier, they frequently fail to remain stable over time, effectively segregating the playground and barring children with disabilities from full participation.
By utilizing modern PIP manufacturing practices, PIP can be made from scratch, specifically for this intended use, to eliminate legacy toxins. With regards to heat, modern PIP often uses lighter color palettes with integrated shading to manage heat.
With these practices, municipalities can provide a playground environment that is both inclusive and safe, balancing minor environmental trade-offs against the profound benefits of total physical accessibility and superior injury protection. • I realize the Resolution will be updated before signing, but in the 'Hereby Certify' section the 'Noes, Absent, and Abstains' should be blank and not pre-populated? Answer: Thank you for the comment. The resolution will be updated prior to signing. • Have these park plans been reviewed by the PARC commission? Answer: The projects are scheduled to be reviewed at the February 17 PARC meeting, at which time the conceptual design could be recommended for approval or altered based on feedback from the public and PARC Commission. Item 4 is to approve entering into an agreement with the recommended vendor/contractor for playground equipment purchase and design so PARC can begin to discuss the porojects. • Was EWF considered as an alternative to PIP surfacing? Answer: Engineered Wood Fiber (EWF) was not considered an alternative to poured-inplace (PIP) safety surfacing. EWF is primarily a cost-effective material and does not provide the same level of accessibility, durability, or consistency as PIP safety surfacing. PIP safety surfacing was selected because it is fully wheelchair accessible, does not require multiple times per day of maintenance, leveling, or cleaning, and
better supports inclusive play and play opportunities for users of all abilities. In addition, PIP safety surfacing is preferred by many families of younger children, as it avoids issues associated with loose materials such as EWF being placed in children’s mouths.
At Shoup Park, the project includes a combination of EWF and safety surfacing to balance cost and accessibility. EWF is used in selected areas where appropriate, while PIP safety surfacing is provided in fall-zone and high-use areas to ensure reliable impact protection and a cleaner, more consistent play experience for both morning and afternoon users.
• Does this analysis provide a reasonable summary of the pros and cons? https://www.fibar.com/blog/poured-in-place-vs.-engineered-wood-fiber-for-playgroundsurfacing Answer: Yes, this link does provide a reasonable summary of the pros and cons of EWF vs PIP. However, because Fibar sells EWF, they are incentivized to frame EWF as "ADA compliant." While it is technically compliant on the day it is installed, it is much harder to keep it that way compared to PIP and requires constant maintenance. In public parks like Grant or Shoup, EWF is regularly displaced, creating "kick-out" pits that immediately compromise both fall safety and ADA accessibility, whereas PIP provides a unitary surface with consistent 24/7 ADA compliance and accessibility as well as fall attenuation.
Additionally, the statement in the article by Fibar—that wheelchairs and strollers can "glide across" EWF without getting stuck—is not consistent with the practical requirements for accessibility in a park environment.
The Fibar analysis is a helpful general guide, but it understates the operational burden of Engineered Wood Fiber and overstates its effectiveness for those who rely on wheelchairs. While EWF is cheaper upfront, it requires constant labor to remain safe and ADA-compliant. For accessibility and fall attenuation, PIP is the more responsible choice because it provides guaranteed accessibility and safety 24/7 without the risk of displacement or "kick-out" pits that occur with loose-fill wood Agenda Item 5 (Grant Park Renovation Acceptance):
• Resolution: The past is the past; while we can reminisce, please update the number of the proposed resolution to 2026.
Answer: Thank you for the comment. The proposed resolution number will be updated to reflect 2026 in the final documents.
• Resolution: The phrase “does hereby finds and authorizes” is not grammatically correct. Please change it to “does hereby find and authorize” or “hereby finds and authorizes” [delete the word “does”].
Answer: Thank you for the comment. The resolution will be updated prior to signing.
• In the Resolution, please update Mayor name.
Answer: The Mayor’s name will be updated in the resolution accordingly. • Why was the final design cost so much lower than budgeted? (Not complaining, obviously. Just curious.)
Answer: The final design cost was significantly lower than budgeted because the original design budget included a conservative allowance based on preliminary scope assumptions and potential complexity. As the project progressed, the scope was refined and streamlined, and much of the work involved standard mechanical and electrical upgrades to existing facilities, which required less design effort than initially anticipated.
Agenda Item 10 (Council Vacancy):
• Although we don’t yet have an estimate for the cost to put an election on the Nov 3 ballot, isn’t it likely that because there are two District seats up for election in November anyway, that any additional seat would have only an incremental cost?
Answer: The vacant seat would be on the November 3, 2026 ballot regardless, as the term expires in November 2026. As such, the November election cost would already include that seat as part of the regularly scheduled municipal election. Staff has not yet received a cost estimate from the Registrar of Voters for November. • My understanding from the County website is that June 2 election results will be certified on July 2, please confirm.
Answer: Correct. The June 2nd election will be certified on Thursday, July 2, 2026.