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Page 1 of 13 40 E San Martin Ave San Martin, CA Preliminary Historic Resource Evaluation & Secretary of the Interior’s Standards Review Prepared for County of Santa Clara Planning and Development San Jose, CA Prepared by Garavaglia Architecture, Inc. June 1, 2020

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40 E San Martin Ave San Martin, CA Preliminary Historic Resource Evaluation & Secretary of the Interior’s Standards Review Prepared for County of Santa Clara Planning and Development San Jose, CA

Prepared by Garavaglia Architecture, Inc. June 1, 2020

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Preliminary Findings, 40 East San Martin Ave

The purpose of this report is to provide preliminary determinations of character-defining features, historical integrity, historic significance, a CEQA impact statement and a project compliance review under the Secretary of the Interior’s Standards for 40 E San Martin Avenue. “Preliminary” here refers to determinations made with partial or incomplete data due to COVID-19 restrictions in place at the time of this reporting. The determinations made here are subject to revision upon completion of a full HRE report when circumstance allows. Following a review of existing documentation and limited additional historic research the property was assessed using landmark designation criteria for the National and State Registers of Historic Places/Resources as well as for Santa Clara County local landmark eligibility. It is the current assessment of GA that 40 E San Martin does not meet National, State or Local criteria to be listed in the State or National Registers, nor to be designated as a local landmark in Santa Clara County, however due to COVID-19 restrictions a definitive conclusion of the site’s significance cannot be reached. Building plans for buildings A and B are held in the Santa Clara County Archive and cannot be accessed. Additionally records regarding tenants on the site at the time of the subject structures’ construction, which may be found in the San Jose History Archive, cannot currently be accessed. As such the owner or lessee of the land at the time of the site’s development cannot be determined and therefore a definitive assessment under Criterion B/2 (Persons) cannot be made. Additionally, the site’s original use is unknown, though it is assumed to have been used as a lumberyard from the time of its construction. An integrity analysis has been preformed on the site to make determinations of the structures’ ability to communicate any potential historic significance they may possess. It is the current assessment of GA that the structures at 40 E San Martin do not maintain a significant degree of integrity due to changes in the site’s associations, appearance, feeling and setting. These changes have rendered the buildings largely unable to communicate any potential significance which may be determined as a result of further research. Finally, as a definitive assessment of historic significance under National, State and Local criteria could not be made at this time, the proposed project has been evaluated for compliance with the Secretary of the Interior’s Standards for the Treatment of Historic Properties and for the significance of impacts under CEQA Guidelines. For the purposes of these evaluations the property was assumed to be historically significant and to retain historical integrity in order to fully asses the impacts the proposed project may have on the site, even if it were determined to be significant following the completion of a full HRE. It is the current assessment of GA that the proposed project is in compliance with the Secretary of the Interior’s Standards for the Treatment of Historic Properties and will not have a significant impact under CEQA Guidelines. Context and Property Description The first peoples to make the Santa Clara Valley their home were the Ohlone, who lived in semi-permanent villages ranging from the Carquinez Strait in the north to Monterey Bay in the south. The valley provided rich foraging and hunting along the many streams and rivers that flow into San Francisco Bay. With the coming of the Spanish to the region following Gaspar de Portolá’s expedition, life in the valley began to orient towards the Mission and settlement at Santa Clara and San Jose, respectively. Large land grants known as Ranchos were awarded to Spanish settlers who began to raise cattle in large numbers. Cattle ranching was to remain the Santa Clara Valley’s major industry until well into the 19th century, even as Mexican independence and the Mexican American War began to bring changes to the region. Following the conclusion of the Mexican American War, 1846-48, California and the Santa Clara Valley became territory of the United States. With the discovery of gold the

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following year, California became an irresistible draw to thousands of migrants. By the 1850’s, failing to strike it rich or simply seeking a more reliable form of income, many began to settle in the southern Santa Clara Valley and began to grow wheat, which until then had been imported to California. The valley soon became an agricultural center, with small towns springing up along the old Camino Real which ran north from Monterey. In the early 1850s Martin Murphy Sr. founded a small settlement and built a church near the foothills east of what is today San Martin. The small agricultural settlement expanded west with the completion of the Santa Clara & Pajaro Railroad line in 1869, creating the footprint of the town we see today. The railroad meant easier and faster transport of goods from the valley, leading to a diversification of crops, especially fruit orchards. San Martin also saw a growth of industry, including lumber milling, logs for which were harvested in the valleys west of town. The transformation of Santa Clara Valley from wheat production to fruit crops was completed by the early 1900’s. The valley became a destination for tourists and by 1930 was producing a large percentage of the world’s fruit supply. The coming of the automobile and the freeway during this time reduced the importance of the railroad and led to the closure of several stops, and the near abandonment of several small towns along the line. San Martin had developed into a large enough town, and its convenient location between Morgan Hill and Gilroy guaranteed its continued growth. The post-war period in San Martin followed a pattern similar to rural towns all throughout California. Agriculture remained dominant, with row crops replacing orchards, but the region also saw a large influx of residents as suburban development expanded and auto transport became ubiquitous. As San Martin began to re-orient towards the freeway, areas along the rail tracks transitioned from commercial use to industrial ones, with lumber, trucking, and auto repair industries concentrated there. San Martin has continued to expand into the present day nearly doubling its population over the last 20 years.1 40 E San Martin Ave is located just east of the former Southern Pacific railroad tracks which run along Monterey road through the center of San Martin. The property comprises an approximately 2-acre rectangular lot which extends south from San Martin Ave along Depot St to just south of Spring St. The lot currently contains four structures referred to as A, B, C and D as well as several concrete parking areas, and the foundation of an older building nearer the train tracks. Building A is an office and warehouse located at the northeast corner of the lot along San Martin Ave and Depot St. it is the only street fronting structure on the lot and is approximately 6,243 sq. feet. Building B is a repair shop located at the southern end of the lot across from Spring street and is approximately 5,025 sq feet. Buildings C and D are sheds located on the southwestern side of the lot nearest the train tracks, they are approximately 330 and 778 sq. feet respectively and are largely hidden from view along Depot St by building B. At least one structure has been removed from the property which can be seen in aerial photographs dating to 1930. A possible foundation of this structure was used as the base for a large canopy structure which was present at the site as late as 2011, as seen on google maps. Ownership of the property has been traced back to 1895 when C. H. Phillips sold the land to the Southern Pacific Railroad. Southern Pacific, later Union Pacific owned the land at least until 1978 when the Weston and Snyder families began operating Wes/Der wood Products Inc on the property. The property was sold in 2016 by the Weston and Snyder family Trusts to Surinder

1DillLeslieA.G.,DuvalCharlene,OosterhousKara,SantaClaraCountyHeritageResourceInventoryUpdate,Shueh,Sam,SouthSantaClaraCounty,Charleston,SC:ArcadiaPublishing,2008.CIRCA:HistoricPropertyDevelopment,HistoricContextStatementfortheCityofMorganHill,MorganHillCalifornia,October2006.SanFranciscoestuaryinstitute,southSantaClaraValleyHistoricalEcologicalStudy,FinalReport,May2008.

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Singh and Balwinder Kaur. 2 The Structures on the site are estimated to have been constructed in 1960, this is based on aerial photography and information from the county assessor. Character-Defining Features 40 E San Martin Ave is characterized as much by its location as it is by architecture, being positioned directly adjacent to the former Southern Pacific Railroad tracks. Industrial construction defines the site and former railroad activity ties it to the small commercial districts on either side of the tracks. Other character-defining features include: • Corrugated metal roofing, siding • Low-height buildings • Street fronting awnings (Building A) • Low pitched gable roofs • Unfinished interior spaces • Muted colors, most are white or earth-tones with some colored trim and accents • Mid-20th Century industrial construction Integrity Integrity is the measure by which properties are evaluated. To retain integrity a property must have most of the seven aspects of integrity as defined by the National Register Criteria for Evaluation. The seven aspects of integrity are quoted as follows: • Location - Location is the place where the historic property was constructed or the place where the historic event occurred. • Design - Design is the combination of elements that create the form, plan, space, structure, and style of a property. • Setting - Setting is the physical environment of the historic property. • Materials - Materials are the physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration form a historic property. • Workmanship - Workmanship is the physical evidence of the crafts of a particular culture or people during any given period in history or prehistory. • Feeling - Feeling is a property's expression of the aesthetic or historic sense of a particular period of time. • Association – Association is the direct link between an important historic event or person and a historic property. According to the Office of Historic Preservation’s Technical Assistance Series Bulletin #6: “Integrity is the authenticity of an historical resource’s physical identity evidenced by the survival of characteristics that existed during the resource’s period of significance. Historical resources eligible for listing in the California Register must meet one of the criteria of significance described above and retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance. It is possible that historical resources may not retain sufficient integrity to meet the criteria for listing in the National Register, but they may still be eligible for listing in the California Register.” Integrity Assessment:

2SantaClaraCounty,California,GrantDeed,Document23224281:1-3,Weston/Snyder&Singh/Kaur,2/16/2016;SantaClaraCountyRecorder,providedbySantaClaraCountyPlanningOffice,4/5/2020.

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Location: The buildings at 40 E San Martin have not been moved from their original locations. Therefore, they possess a high degree of location integrity. Design: Buildings at 40 E San Martin (Building A) have been partially modified from their original form and design, though not all and not extensively. A canopy structure used to store finished lumber was removed from the property impacting the integrity of the sites design and function. Therefore, they maintain a marginal degree of design integrity. Setting: The intersection of E San Martin and Depot Street has remained largely unchanged in overall appearance and scale since the structures at 40 E San Martin were built. They are relatively late additions to the district and were constructed when much of the surrounding areas were already in their current form, with several older buildings along E San Martin and a residential neighborhood developing to the east of Depot Street. However at least one structure has been demolished on the property. Therefore, it retains a marginal degree of integrity of setting. Materials: The exterior finishes, materials, configuration and their current conditions vary greatly across the site. Several alterations or repairs to the materials used within building A have been made including the installation of new window and removal of wooden shingles from its front awning. Buildings B through D appear to be in moderate to poor condition but have few alterations to materials and configuration. 40 E San Martin does not maintain its material integrity. Workmanship: Because the materials used to construct buildings at 40 E San Martin maintain marginal integrity some of the original craftsmanship has been retained. Therefore, 40 E San Martin retains a marginal degree of workmanship integrity. Feeling: The overall sense of place and design associated with 40 E San Martin has been somewhat altered since the construction of the subject buildings. New construction in the area and removal of at least one large structure on the property has diminished the integrity of feeling. Therefore 40 E San Martin retains a marginal degree of integrity of feeling. Association: There is no known association with important people or events in the history of 40 E San Martin Ave. Therefore, it does not possess integrity of association. Preliminary Evaluation of Significance The California Environmental Quality Act (CEQA) requires state and local public agencies to identify the environmental impacts of proposed discretionary activities or projects, determine if these impacts will be significant, and identify alternatives and mitigation measures that will substantially reduce or eliminate significant impacts to the environment. Historical resources are considered part of the environment and a project that may cause a substantial adverse effect on the significance of a historical resource is a project that may have a significant effect on the environment. The definition of "historical resources" is contained in Section 21084.1 of the CEQA Statute as amended January 1, 2005.

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For the purposes of CEQA, an “historic resource” is defined as any resource listed in, or eligible for listing in, the California Register of Historical Resources is presumed to be historically or culturally significant. Further, resources that are listed in a local historic register or deemed significant in a historical resource survey as provided under Section 5024.1(g) are to be presumed historically or culturally significant unless “the preponderance of evidence” demonstrates they are not. National Register of Historic Places: The National Register of Historic Places is the official list of properties, structures, districts, and objects significant in American history, architecture, archeology, engineering, and culture. National Register properties have significance to the prehistory and history of their community, state, or nation. The National Register Criteria for Evaluation is “…the basis for judging a property's significance for their association with important events or persons, for their importance in design or construction, or for their information potential...” National Register Bulletin 15. The National Register Criteria recognizes the following categories: • Criterion A; Associative Value: properties significant for their association or linkages to events • Criterion B; Associative Value: properties significant for their association to persons important to the past • Criterion C; Design or Construction Value: properties significant as representatives of the fabricated expression of culture or technology • Criterion D; Information Value: properties significant for their ability to yield important information about prehistory or history California Register of Historic Places (CRHR): The California Register program encourages public recognition and protection of resources of architectural, historical, archeological and cultural significance, identifies historical resources for state and local planning purposes, determines eligibility for state historic preservation grant funding and affords certain protections under the California Environmental Quality Act. To be potentially eligible for individual listing on the CRHR, a structure must usually be more than 50 years old, must have historic significance, and must retain its physical integrity. In terms of historic significance, the California Register of Historical Resources evaluates a resource based on the following four criteria: • Criterion 1 (Event): Resources 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. • Criterion 2 (Person): Resources associated with the lives of persons important to local, California or national history. • Criterion 3 (Design/Construction): Resources that embody the distinctive characteristics of a type, period, region or method of construction, or that represent the work of a master or possess high artistic values. • Criterion 4 (Information Potential): Resources that have yielded or have the potential to yield information important to the prehistory or history of the local area, California or the nation.

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Santa Clara County Landmark Designation Criteria: ARTICLE II. - LANDMARK DESIGNATION Sec. C17-5. The Board of Supervisors may designate those historic resources as "landmarks" which meet the following designation criteria: • Criterion A; Fifty years or older. If less than 50 years old, sufficient time must have passed to obtain a scholarly perspective on the events or individuals associated with the historic resource and/or the historic resource is a distinctive or important example of its type or style; and • Criterion B; Retains historic integrity. If a historic resource was moved to prevent demolition at its former location, it may still be considered eligible if the new location is compatible with the original character of the property; and • Criterion C; Meets one or more of the following criteria of significance: 1. 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; 2. Associated with the lives of persons important to local, California or national history; 3. 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; or 4. Yielded or has the potential to yield information important to the pre-history or history of the local area, California, or the nation. Evaluations: The following are preliminary evaluations based on available documentation and limited research conducted by Garavaglia Architecture. National Register of Historic Places: • Criterion A; The structures at 40 E San Martin Ave were constructed during a period of expansion in San Martin, that coincided with the profusion of auto transit and suburban development in the larger region. However, while they are representative of a type of industrial warehouse design and construction, that was typical during this period, the associations and setting do not rise to a level of significance that warrants inclusion on the National Register. Therefore, Garavaglia Architecture, Inc. does not find 40 E San Martin to be eligible for consideration for the National Register under Criterion A at any level. • Criterion B; The structures at 40 E San Martin have not been associated with any persons known to be of importance to Local, State, or National History. Therefore, Garavaglia Architecture, Inc. does not find 40 E San Martin to be eligible for consideration for the National Register under Criterion B at any level. This evaluation is preliminary as tenants of the subject property at time of construction cannot be determined due to COVID 19 closures. • Criterion C; The Structures at 40 E San Martin are representative of a modest, midcentury warehouse design. However, the examples are not unique in California or even Santa Clara County. While they exemplify some characteristics of typical warehouse construction they have lost much of their original integrity and do not communicate their potential significance. Therefore, Garavaglia Architecture, Inc. does not find 40 E San Martin eligible for consideration for the National Register as an individual resource under Criterion C at any level. • Criterion D; At this time there is no indication that 40 E San Martin is an area of known pre-historic activity. Generally, because of the extensive ground disturbances on the property dating to driveway construction, site grading and flood control measures taken in the 1970’s, it seems

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unlikely that archaeological materials of any major significance will be found. Therefore, given known data relating to the pre-history of the project site, Garavaglia Architecture, Inc. does not find the property eligible for consideration for the National Register under Criterion D at any level. California Register of Historic Places (CRHR): • Criterion 1 (Event): Even though the California Register has a lower threshold for significance under Criterion 1, Garavaglia Architecture, Inc. does not find 40 E San Martin eligible as an individual resource for the California Register for the reasons stated above under Criterion A of the National Register. • Criterion 2 (Person): Even though the California Register has a lower threshold for significance under Criterion 2, Garavaglia Architecture, Inc. does not find 40 E San Martin eligible as an individual resource for the California Register for the reasons stated above under Criterion B of the National Register. • Criterion 3 (Design/Construction): Even though the California Register has a lower threshold for significance under Criterion 3, Garavaglia Architecture, Inc. does not find 40 E San Martin eligible as an individual resource for the California Register for the reasons stated above under Criterion C of the National Register. • Criterion 4 (Information Potential): Even though the California Register has a lower threshold for significance under Criterion 4, Garavaglia Architecture, Inc. does not find 40 E San Martin eligible as an individual resource for the California Register for the reasons stated above under Criterion D of the National Register. Santa Clara County Landmark Designation Criteria:

San Clara County Landmark designation requires potential resources to meet all criteria to be considered for Landmark Designation. While the Structures at 40 E San Martin are older than 50 years and therefore meet requirements for Criterion A, they do not rise to the level of historic integrity or significance required by Criterion B and C, as detailed in the National Register Criteria, to be considered for local Landmark designation. Preliminary evaluation of proposed project for compliance with the Secretary of the Interior’s Standards for the Treatment of Historic Properties

Because a definitive assessment of 40 E San Martin Ave’s historic significance cannot be made at this time the proposed project at 40 E San Martin Ave will be evaluated for compliance with the Secretary of the Interior’s Standards for Rehabilitation. The proposed project documents were shared with Garavaglia Architecture, Inc. staff. Historic Significance Overview:

The subject property at 40 E San Martin, was found by GA in its preliminarily assessment to be ineligible for listing on the National or California Register of Historic Resources (CRHR) based on the general lack of integrity present, and its lack of known connections to historically significant persons or events. Because comprehensive research into the property is not possible under COVID-19 restrictions an assumption has been made of the property’s historic significance for the purpose of completing this evaluation.

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The proposed plan includes the redevelopment of the subject property 40 E San Martin Ave (APN 825-02-137) as follows. Project Location: The project parcel is largely flat, rectangular shaped, and approximately 2-acres in size. According to project description provided to GA the proposed project area is:

located on a rectangular shaped property bounded on its west by Union Pacific railroad tracks (used for both freight and Caltrans traffic), on the east by residential uses across Depot Street, on its north by the San Martin CalTrain station across East San Martin Avenue, and on the south by another developed parcel (APN 825-02-138) with industrial uses and a telecommunication site. The project site is located approximately 0.60 miles from Highway 101.

The lot contains four buildings described in the project proposal. Building A: A 6,243 sf. office and warehouse building at the property frontage along San Martin Avenue; Building B: A 5,025 sf. repair shop and storage of wood pallets located to the rear of the property; Building C: A 330 sf. office building; and Building D: A 778 sf. shed and restroom building. Project Description:

The proposed Doaba Project Description calls for a “Use Permit and an Architecture and Site Approval (ASA) for the use of existing structures for Truck Sales and Services (as defined in the County Zoning Ordinance) with Repair of small vehicles and light duty trucks.”. Proposed changes to the site are minimal and include the addition of two new access driveways along Depot St, a two-way entrance/exit for customers and a secondary driveway for fire access at the lot’s southern end. The project description states “the existing front porch of Building A is located within a future-width-line of San Martin Avenue, which would require 30 feet of additional width along the property frontage to be dedicated to the County, prior the Building Permit issuance.”. Per discussions with the planning department modifications will be made to the plan to allow for the retention of Building A’s porch, a contributing feature to any potential historical significance of the building. The following compliance evaluations have been completed under the assumption that the porch of building A be retained. Compliance Evaluation:

The Secretary of the Interior’s Standards for Rehabilitation (Standards) lists 10 key elements to consider when new uses or architectural modifications are undertaken within historic resources. The following presents these 10 standards and briefly discusses the level of compliance of the proposed project at 40 E San Martin Ave. For each Standard, a level of compliance is given: Compliant, Marginally Compliant, Not Compliant. A compliant rating indicates that the alteration has little or no impact on the resource. A marginal compliance rating indicates that the overall historical significance of the resource is not impacted enough to warrant re- evaluation, but modifications to the proposed design are strongly recommended. A not compliant rating indicates that the proposed design would severely negatively impact the resource and its eligibility for formal listing on a local, state or national inventory. 1. A property shall be used for its historic purpose or be placed in a new use that requires minimal change to the defining characteristics of the building and its site and environment. The proposed project will shift the site’s use from a wood pallet business to truck sales and services. This use does not significantly differ from the site’s potential historic use which included storage, repair and sales of products used in industrial transport. While the original use of the buildings at time of construction is not definitively known it is likely that its use would be consistent with transportation services as the lot was owned by Southern Pacific Railroad at the time of Building A’s construction (1960). The proposal for the construction of new access driveways will not significantly change the use of the portions of the lot previously used for access to the site, and they will continue to serve their historic purpose. As such, the

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proposed project is compliant with Standard 1. 2. The historic character of a property shall be retained and preserved. The removal of historic materials or alteration of features and spaces that characterize a property shall be avoided. The proposed project will not remove or alter the features of the subject buildings themselves. As previous use included industrial shipping services and the storage of large quantities of industrial products on site no major change to the property’s character has been proposed. As such, the proposed project is compliant with Standard 2. 3. Each property shall be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or architectural elements from other buildings, shall not be undertaken. The proposed work will not be adding conjectural features or architectural elements from other buildings to the existing buildings at 40 E San Martin Ave. There is no proposed work to modify the subject buildings as part of the scope. As such, the proposed project is compliant with Standard 3. 4. Most properties change over time; those changes that have acquired historic significance in their own right shall be retained and preserved. Historic aerial photographs indicate that the two smaller structures, Buildings C and D were constructed after 1960 when the larger structures were built. While the construction date of these two structures is unclear, it is possible that they would fall within any period of significance established by further historic research. The proposed project will not modify or alter the structures as part of this scope. As such, the proposed project is compliant with Standard 4. 5. Distinctive features, finishes, and construction techniques or examples of craftsmanship that characterize a property shall be preserved. The proposed project will not affect distinctive features, construction techniques, or craftsmanship that characterize the property, as there are no proposed changes to the subject buildings as part of this work. However, features that may have characterized the property were removed by previous unpermitted work done on building A. No further alterations are proposed. As such, the proposed project is compliant with Standard 5. 6. Deteriorated historic features shall be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature shall match the old in design, color, texture, and other visual qualities and, where possible, materials. Replacement of missing features shall be substantiated by documentary, physical, or pictorial evidence. The proposed project scope does not include the repair or replacement of any features on the property. As such, the proposed project is compliant with Standard 6. 7. Chemical or physical treatments, such as sandblasting, that cause damage to historic materials shall not be used. The surface cleaning of structures, if appropriate, shall be undertaken using the gentlest means possible. There are no proposed chemical or physical treatments to original materials as part of the scope of work. As such, the proposed project is compliant with Standard 7. 8. Significant archeological resources affected by a project shall be protected and preserved. If such resources must be disturbed, mitigation measures shall be undertaken. No known archeological resources exist at 40 E San Martin. A such the proposed project is compliant with Standard 8.

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9. New additions, exterior alterations, or related new construction shall not destroy historic materials that characterize the property. The new work shall be differentiated from the old and shall be compatible with the massing, size, scale, and architectural features to protect the historic integrity of the property and its environment. While there are currently no proposed modifications to the subject structures at 40 E San Martin Ave previous unpermitted work has affected some potentially historic materials which characterize the property, further discussed in the recommendations. As no new additions or alterations are included the proposed project is compliant with Standard 9. 10. New additions and adjacent or related new construction shall be undertaken in such a manner that if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired. If the proposed new access driveways are to be demolished in the future, the integrity of any historic structures on the property would not be affected, as the site would revert to its previous condition with little change. As such, the proposed project is compliant with Standard 10. Summary and Recommendations:

The proposed project is compliant with Standards 1, 2, 3, 4, 5, 6, 7, 8, 9 and 10 under the assumption that appropriate changes will be made to the proposal in order to retain the potentially significant porch of Building A, located along San Martin Ave and the corner of Depot St. Further it is GA’s recommendation that steps be taken to replace windows, doors, roof singles and wooden siding that was removed during unpermitted work on Building A. Due to the current incompleteness of historic research into the property these characteristics may contribute to the integrity of a potentially historic structure. These recommendations would allow the property to maintain the aesthetic of the site and to appear as less of a modern industrial development.

The inclusion of assumptive changes discussed with the County of Santa Clara Planning Department to the project description - including retaining the porch of building A, and restoring the building to its previous appearance, would render the proposed project compliant with the secretary of the interior’s standards for rehabilitation even in the event that subsequent final determinations of historic significance are made at the conclusion of an HRE process. Impact Analysis under CEQA Guidelines CALIFORNIA ENVIRONMENTAL QUALITY ACT (CEQA) The following sections pertaining to historical resources are excerpted from the Association of Environmental Professional’s 2018 CEQA: California Environmental Quality Act, Statute and Guidelines. 15064.5. Determining the Significance of Impacts to Archaeological and Historical Resources (A) For purposes of this section, the term “historical resources” shall include the following: (1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Pub. Res. Code § 5024.1, Title 14 CCR, Section 4850 et seq.). (2) A resource included in a local register of historical resources, as defined in section 5020.1(k) of the Public Resources Code or identified as significant in an historical resource survey meeting the requirements section 5024.1(g) of the Public Resources Code, shall be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant. (3) Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific,

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economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be “historically significant” if the resource meets the criteria for listing on the California Register of Historical Resources (Pub. Res. Code § 5024.1, Title 14 CCR, Section 4852) including the following:

(a) Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage; (b) Is associated with the lives of persons important in our past; (c) Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or (d) Has yielded, or may be likely to yield, information important in prehistory or history.

(4) The fact that a resource is not listed in, or determined to be eligible for listing in the California Register of Historical Resources, not included in a local register of historical resources (pursuant to section 5020.1(k)of the Public Resources Code), or identified in an historical resources survey (meeting the criteria in section 5024.1(g) of the Public Resources Code) does not preclude a lead agency from determining that the resource may be an historical resource as defined in Public Resources Code sections 5020.1(j) or 5024.1. (B) 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. (1) 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. (2) The significance of an historical resource is materially impaired when a project:

(a) Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register of Historical Resources; or (b) Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to section 5020.1(k) of the Public Resources Code or its identification in an historical resources survey meeting the requirements of section 5024.1(g)of the Public Resources Code, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or (c) Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the California Register of Historical Resources as determined by a lead agency for purposes of CEQA.

(3) Generally, a project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings (1995), Weeks and Grimmer, shall be considered as mitigated to a level of less than a significant impact on the historical resource. (4) A lead agency shall identify potentially feasible measures to mitigate significant adverse changes in the significance of an historical resource. The lead agency shall ensure that any adopted measures to mitigate or avoid significant adverse changes are fully enforceable through permit conditions, agreements, or other measures. (5) When a project will affect state-owned historical resources, as described in Public Resources Code Section 5024, and the lead agency is a state agency, the lead agency shall consult with the

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State Historic Preservation Officer as provided in Public Resources Code Section 5024.5. Consultation should be coordinated in a timely fashion with the preparation of environmental documents. § 21084.1. Historical Resource; Substantial Adverse Change:

A project 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. For purposes of this section, an historical resource is a resource listed in, or determined to be eligible for listing in, the California Register of Historical Resources. Historical resources included in a local register of historical resources, as defined in subdivision (k) of Section 5020.1, or deemed significant pursuant to criteria set forth in subdivision (g) of Section 5024.1, are presumed to be historically or culturally significant for purposes of this section, unless the preponderance of the evidence demonstrates that the resource is not historically or culturally significant. The fact that a resource is not listed in, or determined to be eligible for listing in, the California Register of Historical Resources, not included in a local register of historical resources, or not deemed significant pursuant to criteria set forth in subdivision (g) of Section 5024.1 shall not preclude a lead agency from determining whether the resource may be an historical resource for purposes of this section.

Impacts Analysis: When analyzing whether a proposed project would result in an adverse change to a historical resource, the seven aspects of integrity are considered. Impacts to 40 E San Martin Ave:

The completion of the proposed project would not result in a substantial adverse change to the subject structures at 40 E San Martin Ave. The proposed project would create two access driveways on the property along Depot St, one two-way entrance/exit for customers and a secondary driveway for fire access at the lot’s southern end. The project description also calls for the removal of a porch from building A along San Martin Ave. Per discussions with the Santa Clara County Planning Department this analysis was made under the assumption that the plan be modified to retain the porch of Building A. Therefore, the proposed project would not demolish any physical characteristics of the subject structures at 40 E San Martin Ave. As stated in CEQA Guideline (B, 3) a project determined to be compliant with the Secretary of the Interiors Standards for the Treatment of Historic Properties “shall be considered as mitigated to a level of a less than significant impact on the historical resource.”.

Cumulative Impacts: Future projects in the same vicinity, combined with past alterations, may cumulatively impact the property such that it can no longer communicate any potential historic significance it may possess, to mitigate such impacts GA recommends the site, and specifically Building A, be restored as closely as possible to its condition prior to un-permitted work which removed shingles, wood siding, doors and windows from the building. Overall, the proposed project would not cause a substantial adverse change to 40 E San Martin Ave for the purposes of CEQA review.