Cultural Resource Management Report Irvine Valencia Growers Packing House

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1 Cultural Resource Management Report Irvine Valencia Growers Packing House Including a Phase II Evaluation, Alternatives Analysis Outline, and Mitigation Plan Outline Prepared by: Hatheway & Associates Post Office Box 3246 Crestline, California and The Keith Companies 2955 Red Hill Avenue Costa Mesa, California Principal Investigator, History and Architecture: Roger Hatheway Hatheway & Associates Research Associate: Lora Hatheway Hatheway & Associates Project Manager and Archaeologist: Gavin Archer The Keith Companies Report Submitted January 6, 2003

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3 A Cultural Resources Management Report For The Irvine Valencia Growers Packing House i Table of Contents 1. Abstract...1 Introduction...1 Purpose and Scope of Work...1 Limitations and Exceptions to the Report...2 Proposed Project Description and Location...2 Historical Resources and Environmental Setting...3 Methodology...4 Architectural Description: The Valencia Orange Growers Association Packing House Property and Associated Features...4 Summary Statement: Existing Conditions IVG Packing House and Building Complex...5 Historical Research...5 Historical Summary Statement: Determination of Significance for the Irvine Valencia Growers Packing House...6 Discussion of Alternatives...9 Analysis of Alternatives Thresholds for Determining Significance of Impacts Mitigation Measures Level Of Significance after Mitigation Impacts Overview Mitigation Measures for the Alternatives Environmentally Superior Alternative Introduction Purpose and Scope of Work Summary of CEQA Evaluation Limitations and Exceptions to the Report Project Location and Description Historical Resources and Environmental Setting Historic Preservation Law, Policies, and Mechanisms CEQA Regulatory Requirements Archaeology: Criteria for Evaluation California Register: Criteria for Listing Special (Criteria) Considerations - California Register Methodology Introduction Field Investigations Research Summary Statement - Methodology Architectural Description: The Irvine Valencia Orange Growers Association Packing House Property and Associated Features Historic Description (Appraisal Report) of IVG Buildings and Facilities In Previous Architectural Descriptions... 34

4 ii A Cultural Resource Management Report For The Irvine Valencia Growers Packing House Architectural Description: Existing Conditions...39 Summary Statement - Conclusions: Alterations to IVG Building Complex Historical Background: The Orange Industry and Fruit Packing...43 Sunkist Growers and the Orange Packing Industry in California...43 A Basic Introduction to Growing, Harvesting, and Packing Citrus Background History: The California Cooperative/Association - An International and National Perspective...50 Summary Statement: A Background History of the California Cooperative - An International and National Perspective Historical Background: Orange County, Oranges, and The Irvine Ranch (a Select Reading List)...55 This Was Mission Country Orange County California: The Reflections in Orange of Merle & Mabel Ramsey by Warren F. Morgan...55 Orange County: A Centennial Celebration ( ) by Doris Walker...57 The Historical Volume and Reference Works by Editor Thomas Talbert...62 Orange County by Steve Emmons...65 The Irvine Ranch by Robert Glass Cleland Orange County: The Case of the Disappearing Orange (A Select Reading List)...72 Orange County through Four Centuries by Leo J. Friis...72 The New California: Facing the 21 st Century by Dan Walters...73 A Farewell to the Orange Groves by Marv Wolf, New West Magazine...74 Who Took the Oranges Out of Orange County? The Southern California Citrus Industry in Transition by Edward J. Bachus, Southern California Quarterly Orange County: An Alternate View of the Orange...78 A Century of Citrus by Jim Sleeper, The Santa Ana Register The Packing House and the Rules of the Cooperative/Association...82 Summary Statement: Packinghouses: Vital to the Industry The Packing House as an Operational Entity...85 Summary Statement: The Packing House as an Historic and Operational Entity The Packing House as a Social and Business Entity: An Academic View...90 The Orange County Citrus Strikes of : The Forgotten People in Revolt by Louis Reccow Laboring in the Packing House: Another Academic View...94 Labor and Community; Mexican Citrus Worker Villages in a Southern California County, by Gilbert G. Gonzalez Historical Background: The Railroad and the Irvine Valencia Growers Packing House...99 Santa Fe s Venta Spur by Steve Donalson, Pacific Rail News...99 Summary Statement: Santa Fe s Venta Spur Organization and Business Structure: The Irvine Valencia Growers Packing House Original 1926 Articles of Incorporation of Irvine Valencia Growers Original By-Laws of Irvine Valencia Growers

5 A Cultural Resources Management Report For The Irvine Valencia Growers Packing House iii Meeting Minutes of the Board of Directors and/or Stockholders Construction of the Irvine Valencia Growers Packing House Initial/Preliminary Planning for Construction of a Packing House The Frances Citrus Association Connection Plans Rushed to Build Packing House Acquisition of Land from The Irvine Company Agreement between IVG and the Santa Fe Railroad First Addition to the Packing House Insurance Bond for Addition # Notice of Completion for Addition # Second Addition to the Packing House Notice of Completion for Addition # Summary Statement: Planning, Initial Construction and Early Additions to IVG Packing House Daily Operation of the Irvine Valencia Growers Packing House Job Profiles Summary Statement: Job Descriptions: Irvine Valencia Growers Packing House Trademarks of the Irvine Valencia Growers Packing House Linen Satin Tweed Velvet Madras Irvale Serge An Interesting Historical Sidelight Summary Statement: Trademarks of the Irvine Valencia Growers Packing House A Contemporary (Historic) View of the Irvine Valencia Growers Packing House Citrus Packing Industry Creates Fame for County by Pat Coe, The Santa Ana Register Summary Statement: A Contemporary (Historic) View of IVG Biographical Review: The Irvine Valencia Growers Packing House G. P. Ferrel R. Ferrel William Bradford Hellis The Irvine Company and/or James Irvine George Jeffrey Mary Jeffrey Robert Jeffrey Los Alisos Company A. J. McFadden Ralph J. Mitchell Willis G. Mitchell Owen A. Murray Bennie Osterman J. H. Pankey C. E. Smith

6 iv A Cultural Resource Management Report For The Irvine Valencia Growers Packing House George H. Veeh Herbert Walker Walter West John L. Wheeler Summary Statement: A Biographical Review of IVG Historical Summary Statement: Determination of Significance for the Irvine Valencia Growers Packing House 152 State: California Register Items (1-4) Summary: California Register Summary: Potential as District Contributor Discussion of Alternatives Defining the Alternatives for Analysis Analysis of Alternatives Thresholds for Determining Significance of Impacts CEQA Guidelines Standards for Treatment of Historic Properties Thresholds for Cumulative Impacts Approach to Evaluating Impacts to Historic Districts Summary Statement: District Impacts Mitigation Measures Introduction HABS Outline Format Documentation Level of Significance after Mitigation Impacts Overview Growth Inducing Impacts Cumulative Impacts Significant Unavoidable Adverse Impacts Significant Irreversible Environmental Change Mitigation Measures for the Alternatives Environmentally Superior Alternative Bibliography Books and Reports City Directories Libraries Maps/Drawings Newspapers Periodicals Technical Bulletins And Reports Respondents Minutes of the Board of Directors Meetings Minutes of Stockholders Meetings Articles of Incorporation and By-Laws Real Estate Options

7 A Cultural Resources Management Report For The Irvine Valencia Growers Packing House v Correspondence/Miscellaneous Documents Appraisal Reports Valuable Trade-Mark Records Employee Job Descriptions

8 vi A Cultural Resource Management Report For The Irvine Valencia Growers Packing House Appendices Appendix A - Figures...A-1 Figure 1 - Vicinity Map... A-2 Figure 2 - Location Map. Tustin 7.5 minute quadrangle map showing Kathryn Station and IVG packing house general site plan (photorevised 1981)... A-3 Figure 3 - Historic 1945 Santa Ana topography map showing Kathryn and Frances packing houses/sidings (railroad alignment highlighted). 15 minute quad.... A-4 Figure 4 - Original (1929) IVG site/building plan.... A-5 Figure 5 - Contemporary aerial.... A-6 Figure 6 - Site plan (existing) IVG packing house. 30th Street Architects.... A-7 Figure 7 - Section/upper floor packing house. 30th Street Architects.... A-8 Figure 8 - Lower floor IVG packing house.... A-9 Figure 9 - Pre cooler section/floor plan. 30th Street Architects.... A-10 Figure Insurance appraisal map. Site plan and building location/use.... A-11 Appendix B - Photographs...B-1 Photograph 1 - Irvine Valencia Growers packing house. Overall view looking westerly along Jeffrey. View azimuth 210 degrees... B-2 Photograph 2 - Irvine Valencia Growers packing house. Overall view looking easterly along Jeffrey. View azimuth 45 degrees.... B-3 Photograph 3 - Irvine Valencia Growers packing house. Overall view looking northerly. View azimuth 310 degrees... B-4 Photograph 4 - Irvine Valencia Growers packing house. Overall view packing house east elevation. View azimuth 170 degrees... B-5 Photograph 5 - Irvine Valencia Growers packing house. Overall view packing house / pre cooler east elevation. View azimuth 270 degrees... B-6 Photograph 6 - Irvine Valencia Growers packing house. Entry elevation (north) packing house. View azimuth 160 degrees... B-7 Photograph 7 - Irvine Valencia Growers packing house. Overall packing house / sheds along Jeffrey. View azimuth 80 degrees.... B-8 Photograph 8 - Irvine Valencia Growers packing house. Packing house skylight detail.... B-9 Photograph 9 - Irvine Valencia Growers packing house. Packing house loading platform shed. View azimuth 140 degrees...b-10 Photograph 10 - Irvine Valencia Growers packing house. Detail: basement access ramp north elevation....b-11 Photograph 11 - Irvine Valencia Growers packing house. Detail: basement access ramp south elevation...b-12 Photograph 12 - Irvine Valencia Growers packing house. Interior packing house main floor looking southerly...b-13 Photograph 13 - Irvine Valencia Growers packing house. Interior packing house basement...b-14 Photograph 14 - Irvine Valencia Growers packing house. Detail: connection between packing house and pre cooler...b-15 Photograph 15 - Irvine Valencia Growers packing house. Overall pre cooler south and west elevations. View azimuth 340 degrees....b-16 Photograph 16 - Irvine Valencia Growers packing house. South elevation refrigeration and equipment. View azimuth 270 degrees...b-17 Photograph 17 - Irvine Valencia Growers packing house. Easterly elevation pre cooler. View azimuth 295 degrees...b-18

9 Phase II Cultural Resources Management Report The Irvine Valencia Growers Packing House vii Photograph 18 - Irvine Valencia Growers packing house. Detail: pre cooler art deco influence. View azimuth 225 degrees....b-19 Photograph 19 - Irvine Valencia Growers packing house. Office building (13248). View azimuth 105 degrees....b-20 Photograph 20 - Irvine Valencia Growers packing house. Overall view metal sheds. View azimuth 140 degrees....b-21 Photograph 21 - Irvine Valencia Growers packing house. Construction detail metal shed....b-22 Photograph 22 - New (non-historic) fruit packing building. View azimuth 155 degrees...b-23 Photograph 23 - Gargiulo packing building (13252 Jeffrey). View azimuth 90 degrees....b-24 Photograph 24 - Irvine Farm Management (13256 Jeffrey). View azimuth 240 degrees...b-25 Photograph 25 - Irvine Packing & Cooling (13250 Jeffrey). View azimuth 240 degrees....b-26 Photograph 26 - Home of entry sign for building complex businesses...b-27 Photograph 27 - Gas pumps. View azimuth 345 degrees...b-28 Photograph 28 - IVG office / mobile offices. View azimuth 165 degrees...b-29 Photograph 29 - Entry sign along Jeffrey: Irvine Packing & Cooling....B-30 Appendix C - Amended DPR 523 Form... C-1 Appendix D - Qualifications...D-1

10 viii A Cultural Resource Management Report For The Irvine Valencia Growers Packing House

11 Phase II Cultural Resources Management Report The Irvine Valencia Growers Packing House 1 1. Abstract Introduction This report represents an in-depth historical research effort providing a sufficient level of detail to evaluate the Irvine Valencia Growers Packing House within a fully developed historical context. The level of information gathered allows for the placement of the Irvine Valencia Growers Packing House, as required by CEQA, into the broad patterns of local or regional history, or the cultural heritage of California or the United States. The historical context and cultural resource evaluation portions of this report are complete and fully compliant with CEQA. For planning purposes, impacts, alternatives, and mitigation options are overviewed and discussed. These portions of the report, while based on substantive information, are intended as outlines only. Impacts, alternatives, and mitigation options should be further and more specifically analyzed and developed. Purpose and Scope of Work During the period extending from June 10, 2002 to June 30, 2002 the following report entitled, A Cultural Resource Management Report for the Irvine Valencia Growers Packing House, was prepared by Hatheway & Associates under California Environmental Quality Act (CEQA) Guidelines for the Keith Companies Inc., Costa Mesa, California. This report was prepared to determine the historical and architectural significance of the Irvine Valencia Growers Packing House and known or potential cultural resources associated with it. This report is classed as a Phase II evaluation in full compliance with CEQA Guidelines. In addition, Discussion of Alternatives, Thresholds for Determining Significance of Impacts, Mitigation Measures, and Impacts Overview outlines are provided for planning purposes only. In addition, this report has been prepared in accordance with the conditions, conclusions, and recommendations as contained in the August 22, 2001 report entitled, A Phase I Cultural Resources Inventory for Planning Area 9 Irvine, California, as prepared for the Irvine Community Development Company by The Keith Companies, Inc. The preparation of this report was designed to maximize the level of information gathered. Principals, specialists, and/or professionals were utilized throughout. Roger G. Hatheway served as the Principal Investigator, and was assisted by a qualified research associate. Mr. Hatheway has 26 years of qualifying experience as a Cultural Resource Management (CRM) specialist, having actively worked in the field of historic preservation for the entire period of time extending from 1976 to the present. Hatheway & Associates has prepared studies, extending nationwide, for a wide variety of federal, state, county, city and private clients.

12 2 For The Irvine Valencia Growers Packing House Limitations and Exceptions to the Report All conclusions and recommendations contained herein are based solely on studies as conducted within the defined and agreed upon scope of services. All opinions expressed are based on experience with similar studies, and on information gathered as part of the specific proposed investigation. The opinions contained in this report are based on visual observations made at the project site, on data gathered as part of the proposed historical and archival research process, and on information provided, in part, to Hatheway & Associates. If additional information is made available, and/or physical conditions change at the project site, Hatheway & Associates reserves the right to modify any and all opinions expressed. Any use of information contained in this report, or reliance on the conclusions and recommendations of this report for purposes other than those as stated in the proposal/scope of services, shall be the sole responsibility and liability of the party undertaking such use. Hatheway & Associates makes no warranty as to the accuracy of information provided by others as contained and/or quoted in this report, nor are there any other warranties or guarantees, either intended or implied, apart from the fact that the document has been prepared in accordance with accepted standards, practices, and guidelines similar to other Cultural Resource Management (CRM) specialists. Finally, none of the work conducted or any of the opinions expressed as part of the conclusions and recommendations of this report shall be regarded as or constitute a legal or binding opinion of any nature whatsoever. Specifically, the ultimate decision as to the significance of properties in the State of California rests with the Office of Historic Preservation and/or the California State Historic Resources Commission. Proposed Project Description and Location The packing house complex is located on the east side of Jeffrey Road between Trabuco Road and Irvine Boulevard (13000 block of Jeffrey Road) in unincorporated Orange County, California (see Appendix A, Figures 1-5). It lies in Planning Area 9 and the planned Jeffrey Open Space Spine (JOSS). The JOSS is a planned passive recreation and open space corridor running along the east side of Jeffrey Road between the Santa Ana (Interstate 5) Freeway and the open space area north of Portola Parkway. The spine will be 325 feet wide and total 117 acres. The land is currently under County of Orange jurisdiction and zoned for agricultural use. Rezoning of the JOSS for recreation-open space use and of the surrounding Northern Sphere for commercial and residential use is in progress. The City of Irvine plans to annex the Northern Sphere, including the JOSS land. The spine will have a park-like look, with trails meandering down the eastern side of Jeffrey Road. Parking will be available near the packing house site and toward the northern end of the spine. Design alternatives for the packing house include rehabilitation and conversion to mixed recreationcommercial use or demolition.

13 Phase II Cultural Resources Management Report The Irvine Valencia Growers Packing House 3 Historical Resources and Environmental Setting This report has been prepared in general accordance with CEQA Guidelines. Specifically, archaeological and historical resources are protected on private land by the California Environmental Quality Act (statute as amended January 1, 2001 Legislation: Guidelines as amended February 1, 2001). Appendix G Part (j) of the CEQA Guidelines specifies that a project will normally have a significant impact on the environment if it disrupts or adversely affects a prehistoric or historic archaeological site or a property of historic or cultural significance to a community or ethnic or social group. Appendix K of the CEQA Guidelines further specifies that CEQA applies to historic and prehistoric archaeological resources, and that public agencies should seek to avoid damaging effects on archaeological resources whenever feasible. If avoidance is not feasible, then Appendix K provides guidance on mitigating significant impacts. Note: Archaeological resources are not a part of the present report. These are addressed in the previously mention Keith Companies 2001 report entitled, A Phase I Cultural Resources Inventory for Planning Area 9 Irvine, California. As required by CEQA Guidelines, portions of the present report analyze the potential historic resource impacts of the proposed project. The Environmental Setting discussion provides background information on: 1. Historic preservation law, preservation policies, and preservation mechanisms at the state level. 2. The potential historic nature/significance of existing structures on the project site. The Thresholds for Determining Significance discussion explains the nature of an historic resource impact, as defined by CEQA. The Project Impacts discussion addresses three main questions: (1) does the project area contain a significant historic resource; (2) will the project result in a significant impact to historic resources; and (3) will the project result in a significant impact to any historic district? The Mitigation section explains what is required to mitigate an historic resource impact and identifies any feasible mitigation measures for project impacts. Finally, the Level of Significance portion of this section identifies whether there are any historic resource impacts of the proposed project that cannot be mitigated.

14 4 For The Irvine Valencia Growers Packing House Methodology Field Investigations Various field studies were conducted beginning on June 10, All building features within and/or in the immediate vicinity of the project area were photographed, and field notes were taken for use in the preparation of written architectural descriptions. Additional photographs of the interior of the Packing House were taken on June 11, Research Meetings were also held June 10, 2002 with Irvine Valencia Growers office staff and Keith Companies staff regarding the acquisition of all previous reports/surveys regarding the property, and the acquisition of important historical records and access to archives pertaining to the historical growth and development of the property. The Special Collections at the University of California, Irvine (UCI) were consulted over a period of two days. At UCI, numerous references were collected regarding the orange industry in Orange County. Architectural Description: The Valencia Orange Growers Association Packing House Property and Associated Features The IVG facility has been described several times prior to preparation of the present report. Most notably, it was described: 1. in a 1976 Insurance Appraisal report as prepared by General Appraisers, 2. in a Feasibility Study for Adaptive Reuse Irvine Valencia Packing House and Pre Cooler Building, as prepared for the City of Irvine by Thirtieth Street Architects, Inc., and dated September 6, 2001, 3. and in an August 22, 2001 report entitled, A Phase I Cultural Resources Inventory for Planning Area 9 Irvine, California, as prepared by The Keith Companies, Inc. Each of the above noted descriptions has been reviewed, and significant elements incorporated into the Architectural Description: Existing Conditions section of this report.

15 Phase II Cultural Resources Management Report The Irvine Valencia Growers Packing House 5 Summary Statement: Existing Conditions IVG Packing House and Building Complex Today, virtually the entire site may be considered an alteration to the original Irvine Valencia Growers (IVG) building complex. Specifically, a comparison of historic maps to existing conditions reveals that numerous changes have taken place since construction of the facility beginning in The complex was completed in In summary, the original architectural integrity of the 1928/1929 IVG Packing House Building Complex has been severely compromised. The Main Building/Packing House has also been altered. Many of these alterations, however, including the 1931 addition and the 1937 Pre Cooler and Refrigeration Building additions, are historic. Finally, the overall architectural significance of the Historic Building Complex is minimal, as the design is similar to many Utilitarian/Industrial buildings constructed nationwide during the period extending from the 1920s to the 1950s. The Pre Cooler Building is minimally influenced by Art Deco applied decorative detail, but this influence must be regarded as being of secondary importance. Historical Research This report represents a massive research effort. This level of research was undertaken in recognition of the fact (results of field survey) that the ultimate determination of significance would likely be made as based upon historical information and not on architectural merits. Sections of this report containing historical material pertaining directly to the history, construction, and operation of the Irvine Valencia Growers Packing House and Building Complex and/or the significance of various aspects of the orange industry in Orange County are:?? Historical Background: The Orange Industry and Fruit Packing?? Sunkist Growers and the Orange Packing Industry in California?? A Basic Introduction to Growing, Harvesting, and Packing Citrus?? Background History: The California Cooperative/Association -- An International and National Perspective?? Historical Background: Orange County, Oranges, and The Irvine Ranch (A Select Reading List)?? Orange County: The Case of the Disappearing Orange (A Select Reading List)?? Orange County: An Alternate View of the Orange?? The Packing House and the Rules of the Cooperative/Association?? The Packing House as an Operational Entity?? The Packing House as a Social and Business Entity: An Academic View?? Laboring In The Packing House: Another Academic View?? Historical Background: The Railroad and The Irvine Valencia Growers Packing House?? Organization and Business Structure: The Irvine Valencia Growers Packing House?? Construction of the Irvine Valencia Growers Packing House

16 6 For The Irvine Valencia Growers Packing House?? Daily Operation of the Irvine Valencia Growers Packing House?? Trademarks of the Irvine Valencia Growers Packing House?? A Contemporary (Historic) View of the Irvine Valencia Growers Packing House?? Biographical Review: The Irvine Valencia Growers Packing House Historical Summary Statement: Determination of Significance for the Irvine Valencia Growers Packing House Note: The following conclusions are made based upon a field survey, and an in-depth archival research program in accordance with CEQA Guidelines. State: California Register Items (1-4) 1. It is associated with 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. The IVG Packing House and Historic Building Complex does appear to qualify as eligible for listing in the California Register of Historic Places in relation to this item. Numerous significant events are discussed in detail in sections of this report entitled:?? Background History: The California Cooperative/Association - An International and National Perspective;?? Historical Background: Orange County, Oranges,?? The Irvine Ranch (A Select Reading List); and?? Orange County: The Case of the Disappearing Orange (A Select Reading List) The most significant events that the Irvine Valencia Growers Packing House and Building Complex is associated with and/or that have made a significant contribution to the broad patters of California local history are: 1. The development of the California citrus industry and the California Cooperative. 2. The development of the Valencia orange industry in Orange County. Note here that the Valencia was identified at the official tree of Orange County in The development of The Irvine Ranch and/or The Irvine Company, and as a representative example of how the pervasive influence of the company was expressed in a version of the California Cooperative. 4. The association of the IVG Packing House with the Citrus Strikes of , and the significance of this event in the labor history of Orange County.

17 Phase II Cultural Resources Management Report The Irvine Valencia Growers Packing House 7 5. The association of the IVG Packing House with the decline of the orange industry in Orange County, and as a symbol of time and time past. 6. As an example of a packing house as a social, cultural, and business entity in California. These events are of true and undoubted significance. Additional events might also be considered (the role of the railroad, etc.), but the identified events (relevant to the broad patterns of California history) are sufficient to warrant a positive determination of significance in relation to this item. 2. It is associated with the lives of persons important to local, California or national history. The IVG Packing House and Historic Building Complex does not appear eligible to the California Register in relation to this item. Despite the fact that the biographical research effort was limited to some degree by the sheer number of individuals associated with the IVG Packing House, it is unlikely that additional biographical information would identify any individual of overwhelming local significance or importance in relation to the IVG Packing House. Very simply, every individual researched, and for whom some information has been found, has some local significance. However, it must be understood that these individuals were a part of an Association and that no single individual researched had a singular influence on the establishment, construction, growth, and/or development of either IVG as a business or the IVG Packing House. Specifically, their individual home might be of significance (if it remains standing today), but the IVG Packing House cannot be regarded as significant in association with any one individual. This would include James Irvine himself. His signature is on the Land Conveyance document giving title of Irvine Company lands to IVG, but if every property having Irvine s signature on a document related to it were made significant, then half of Orange County would be potentially significant. No significant individual may, therefore, be said to be associated with the IVG Packing House. Rather, the IVG Packing House is here regarded as an event in the development history of Orange County (see Item #1). 3. 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. The IVG Packing House and Historic Building Complex does not appear eligible to the California Register in relation to this item. Today, virtually the entire site may be considered an alteration to the original Irvine Valencia Growers (IVG) building complex. Alterations to the historic IVG Packing House Building Complex include the following: Addition to Main Building/Packing House 2. Circa 1937 Pre Cooler Addition and 1969 Pre Cooler Addition Refrigeration and Equipment Storage Building 4. Demolition of Original Office Building (In Front of Main Building) 5. Shed Additions (Eventual Demolition of Several) 6. Garage and Storage Building Addition (Eventual Demolition of Same)

18 8 For The Irvine Valencia Growers Packing House 7. Boiler House Construction 8. Demolition of Several Equipment/Yard Features (Pump House, Etc.) 9. Construction of Present Irvine Packing & Cooling Building 10. Construction of Additional Fruit Packing Buildings 11. Construction of Irvine Farm Management Buildings 12. Numerous Small Additions (Platforms/Sheds/Docks) In summary, the original architectural integrity of the 1929 IVG Packing House Building Complex has been severely compromised. The Main Building/Packing House has also been altered. Many of these alterations, however, including the 1931 addition and the 1937 Pre Cooler and Refrigeration Building additions, are historic. Regardless, the primary significance of the packing house is not related to architecture. Rather, the IVG Packing House is best regarded as an event in the development history of Orange County (see Item #1). Finally, the overall architectural significance of the Historic Building Complex is minimal, as the design is similar to many Utilitarian/Industrial buildings constructed nationwide during the period extending from the 1920s to the 1950s. The Pre Cooler Building is minimally influenced by Art Deco applied decorative detail, but this influence must be regarded as being of secondary importance. 4. It has yielded or has the potential to yield information important to the prehistory or history of the local area, California or the nation. This Item is primarily related to archaeological concerns. The IVG Packing House and Historic Building Complex does not appear to qualify as eligible for listing in the California Register of Historic Places in relation to Item #4 at the present time. No previously identified archaeological resources are known to be associated with the project area, and no resources were identified during the survey conducted as part of the present study. Summary: California Register The IVG Packing House and Historic Building Complex does appear to qualify as eligible for listing in the California Register of Historic Places in relation to Item #1. Summary: Potential as District Contributor This building does not appear to qualify as eligible for listing as a contributing feature to any type of architectural and /or historic district in accordance with California Register guidelines.

19 Phase II Cultural Resources Management Report The Irvine Valencia Growers Packing House 9 Discussion of Alternatives Note: This section is an outline only. Alternatives and mitigation options should be analyzed and discussed more fully and specifically. Defining the Alternatives for Analysis According to Section of the CEQA Guidelines: An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation. Alternatives and Their Relationship To Project Impacts The alternatives included in the document are designed to address impacts according to CEQA Guidelines Section (b)(1): Where maintenance, repair, stabilization, rehabilitation, restoration, preservation, conservation or reconstruction of the historical resource will be conducted in a manner consistent with the Secretary of the Interior s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings (1995), Weeks and Grimmer, the project s impact on historical resources shall generally be considered mitigated below a level of significance and thus is not significant. Alternatives that are designed to comply in part or in full with the Secretary of the Interior s Standards would avoid or substantially lessen historic resource impacts. A brief background on the Secretary of the Interior s Standards is provided below. Secretary of the Interior s Standards The Secretary of the Interior s Standards for the Treatment of Historic Properties (Standards for Treatment of Historic Properties) provide four treatment approaches for dealing with historic structures:

20 10 For The Irvine Valencia Growers Packing House 1. Preservation This is defined as the act or process of applying measures necessary to sustain the existing form, integrity, and materials of an historic property: - Work, including preliminary measures to protect and stabilize the property, generally focuses upon the ongoing maintenance and repair of historic materials and features rather than extensive replacement and new construction. - Exterior additions are not within the scope of this treatment. - The limited and sensitive upgrading of mechanical, electrical, and plumbing systems and other code-required work to make properties functional is appropriate within a preservation project. 2. Restoration This is defined as the act or process of accurately depicting the form, features, and character of a property as it appeared at a particular period of time by means of the removal of features from other periods in its history and reconstruction of missing features from the restoration period. 3. Reconstruction The act or process of depicting, by means of new construction, the form, features, and detailing of a surviving or non-surviving site, landscape, building, structure, or object for the purpose of replicating its appearance at a specific period of time and in its historic location. 4. Rehabilitation The act or process of making possible a compatible use for a property through repair, alterations, and additions while preserving those portions or features that convey its historical, cultural, or architectural values. The two alternatives included in this document that address potential historic resource impacts are examples of restoration, reconstruction, and rehabilitation treatments. Relocation of the building is not presented as an alternative. The State Historic Resource Commission discourages removal from historical location (see Chapter 5). The resource s significance is largely association with events, not architectural. Even if a new location were compatible with the building s original character and use, relocation would not substantially lessen project impacts. Analysis of Alternatives Alternative #1 - No Project/No Change Note: The following alternative analysis applies to the No Project/No Change Alternative as well as the Preservation and Restoration of Existing Building Alternative.

21 Phase II Cultural Resources Management Report The Irvine Valencia Growers Packing House 11?? Historic Resources This alternative would result in no impacts to historic resources.?? Feasibility This alternative presents feasibility constraints with regards to the long-term operation of the facility.?? Project Objectives This alternative would not achieve the City s objective of providing additional recreational opportunities through the Jeffrey Open Space Spine project. Alternative #2 - Preservation, Restoration and Adaptive Reuse of Packing House Building Complex This alternative would result in beneficial impacts to historic resources, through the preservation and restoration of the IVG Packing House.?? Feasibility A number of feasibility constraints are associated with this alternative. Specifically, the restoration and preservation of the IVG Packing House building would be a time consuming and expensive proposition. Meeting current building codes and reversing the numerous alterations to the building units are also a consideration. The Feasibility Study for Adaptive Reuse, Irvine Valencia Packing House and Pre Cooler Building, prepared for the City of Irvine by Thirtieth Street Architects, Inc., and dated September 6, 2001, estimated a cost of approximately $14M to $16M for preservation, restoration, and adaptive reuse.?? Project Objectives The cost of preservation and restoration would reduce the City s ability to provide additional recreational opportunities through the Jeffrey Open Space Spine project as planned. Alternative #3 - Preservation of Original Old Packing House Building Only?? Historic Resources This alternative would have a minimal impact on historic resources as it would first involve the demolition of a portion of the building complex (Pre Cooler, Refrigeration Building, and metal sheds) prior to reconstruction and preservation of the Old Main Building. The main building is, in fact, the original packing house, and the preservation and restoration of this building unit would result overall in beneficial impacts to historic resources.

22 12 For The Irvine Valencia Growers Packing House?? Feasibility A number of feasibility constraints are associated with this alternative. Specifically, the restoration and preservation of the IVG Packing House main building would be a time consuming and expensive proposition. Meeting current building codes, and reversing the numerous alterations to the building units are also a consideration. The Feasibility Study for Adaptive Reuse, Irvine Valencia Packing House and Pre Cooler Building, prepared for the City of Irvine by Thirtieth Street Architects, Inc., and dated September 6, 2001, estimated a cost of approximately $14M to $16M for preservation, restoration, and adaptive reuse.?? Project Objectives The cost of preservation and restoration would reduce the applicant s ability to provide additional recreational opportunities through the Jeffrey Open Space Spine project as planned. Thresholds for Determining Significance of Impacts CEQA Guidelines According to CEQA Guidelines: A project with an effect that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment. Substantial adverse change in the significance of an historical resource means physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired. The significance of an historical resource is materially impaired according to CEQA Guidelines (4)(b)(2) when a project: (A) (B) (C) Demolishes or materially alters in an adverse manner those physical characteristics of an historic resource that convey its historic significance and that justify its inclusion in, or eligibility for, inclusion in the California Register of Historical Resources; or Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to (k) of the Public Resources Code or its identification in an historic resources survey meeting the requirements of (g) of the Public Resources Code, unless the public agency reviewing the effects of the project establishes by a preponderance of the evidence that the resource is not historically or culturally significant; or Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historic significance and that justify its eligibility

23 Phase II Cultural Resources Management Report The Irvine Valencia Growers Packing House 13 for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA. Standards for Treatment of Historic Properties According to CEQA Guidelines: Generally, a project that follows the Secretary of the Interior s Standard for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior s Standards for Rehabilitation and Guidelines for Rehabilitation of Historic Buildings (1995), Weeks and Grimmer, shall be considered as mitigated to a level of less than a significant impact on the historical resource. Thresholds for Cumulative Impacts A cumulative impact occurs when a proposed project, in combination with other past, current and probably future projects will have an impact on the environment. ***** As noted previously, this Thresholds for Determining Significance discussion explains the nature of an historic resource impact, as defined by CEQA. Specifically, 1. Does the project area contain a significant historic resource? The Irvine Valencia Growers Packing House has been identified as a potentially significant historic resource in relation to California Register of Historic Places guidelines (Criterion 1). 2. Will the project result in a significant impact to historic, architectural, and/or archaeological resources? The proposed project will result in a significant impact to a potentially significant historic resource (The IVG Packing House) in relation to Threshold (A). 3. Will the project result in a significant impact to any historic district? Neither CEQA nor OHP provides guidance on specific thresholds of significance to use when evaluating potential impacts to historic districts verses impacts to individual buildings determined to be historical resources. In addition, neither CEQA nor the OHP provides specific guidance on how much material alteration can occur to a district, before it loses its historical significance.

24 14 For The Irvine Valencia Growers Packing House National Register Bulletin 15 does provide some general guidelines for determining whether a district retains its integrity. According to the Bulletin: For a district to retain integrity as a whole, the majority of the components that make up the district s historic character must possess integrity even if they are individually undistinguished. In addition, the relationship among the district s components must be substantially unchanged since the period of significance. When evaluating the impact of intrusions upon the district s integrity, take into consideration the relative number, size, scale, design, and location of the components that do not contribute to the significance. A district is not eligible if it contains so many alterations or new intrusions that it no longer conveys the sense of a historic environment. No district has been identified in association with the IVG packing house. Summary Statement: District Impacts The project will not have a significant impact on any future proposed architectural or historical district. Mitigation Measures CEQA Guidelines provide the following guidance in determining whether impacts to an historic resource have been fully mitigated: (1) Where maintenance, repair, stabilization, rehabilitation, restoration, preservation, conservation or reconstruction or the historical resource will be conducted in a manner consistent with the Secretary of the Interior s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitation, Restoring, and Reconstructing Historic Buildings (1995), Weeks and Grimmer, the project s impact on the historical resource shall generally be considered mitigated below a level of significance and thus is not significant. Alternatives that provide varying degrees of mitigation pursuant to (1) above are presented in the Discussion of Alternatives section of this report. (2) In some circumstances, documentation of an historic resource, by way of historic narrative, photographs or architectural drawings, as mitigation for the effects of demolition of the resource will not mitigate the effects to a point where clearly no significant effect on the environment would occur.

25 Phase II Cultural Resources Management Report The Irvine Valencia Growers Packing House 15 Architecture The following mitigation measure, pursuant to (b) of the CEQA Guidelines, will reduce but not eliminate significant project impacts: A HABS outline format narrative description of the property, contemporary and historic photographs, and other relevant documentation shall be prepared by a historic consultant approved by the City. The report shall be submitted for approval to the Planning Director of Irvine, and an approved original deposited in the City of Irvine Public Library (or other suitable repository) prior to issuance of the demolition permit for the subject property. Level Of Significance after Mitigation The proposed mitigation measures will reduce, but not eliminate: Significant impacts to potential historic/architectural resources on the project site (Threshold A) resulting from their demolition. Project impacts to historical resources will remain significant after mitigation. Impacts Overview Growth Inducing Impacts The proposed project is growth inducing as it would foster population growth. Cumulative Impacts A cumulative impact occurs when a proposed project, in combination with past, present and probable future developments, produces an impact which is considerable. No significant cumulative impacts on cultural resources are anticipated with regards to the proposed project (Please refer to the August 22, 2001 report entitled, A Phase I Cultural Resources Inventory for Planning Area 9 Irvine, California, as prepared for the Irvine Community Development Company by the Keith Companies Inc). The proposed project is, at the present time, the only major project that could adversely affect the potential historical significance of the IVG Packing House and building complex. The buildings are not associated with any proposed or potential architectural district. No other projects that would

26 16 For The Irvine Valencia Growers Packing House affect this potential are currently proposed. There are, therefore, no cumulative historic resource impacts. Significant Unavoidable Adverse Impacts The proposed project would result in the following unavoidable adverse impacts: The proposed project would result in significant unmitigated impacts to a potential historic resource as a result of the demolition of that resource. The project as proposed will result in significant unmitigated historic resource impacts to architectural resources (The IVG Packing House Building Complex) on the site. Significant Irreversible Environmental Change The proposed project would result in the irreversible loss of a potential historic resource. This would be an irreversible effect of the proposed project. Mitigation Measures for the Alternatives The following mitigation measure would apply to all but the No Project/No Change alternative, in order to ensure that development is consistent with any alternative approved by the City of Irvine. Documentation: Prior to any demolition or significant modification of buildings on the project site, a HABS outline format narrative description of the property, contemporary and historic photographs, and other relevant documentation shall be prepared by a historic consultant approved by the City of Irvine. The report shall be submitted for approval to the Planning Director of the City of Irvine and an approved original deposited in the City of Irvine Public Library (or other suitable repository) prior to issuance of the demolition permit for the project. Environmentally Superior Alternative All of the alternatives are environmentally superior to the proposed project that would result in the demolition of the IVG Packing House.

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