CORRESPONDENCE - 75A SEXLINGER FARMHOUSE

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ARCHITECT MILFORD WAYNE DONALDSON FAIA Orchard, preserving only 10 trees with space for planting up to 6 new orange trees. The environmental impact report (EIR) for the demolition concludes that preservation of 10 to 16 trees in a single row on a one - quarter acre corner of the Orchard will not have a significant adverse impact on the historic significance of the Sexlinger property. The proposal to demolish 95 percent of the Orchard does not comply with the Secretary's Standards, even when combined with retention and rehabilitation of the Farmhouse. The Orchard and Farmhouse currently have a high degree of integrity that reflects their historic use. Loss of 95 percent of the Orchard would cause a significant loss of integrity, and would affect those features and characteristics that qualified the combined Orchard and Farmhouse for listing on the National and California Registers. It is my understanding that the Council recognized the historic significance of the entire property, including both the Orchard and Farmhouse, when it designated them together in the "Key" resource designation. Demolition of the majority of the Orchard would cause the Sexlinger property to lose its historic significance. Loss of significance, as well as the loss of contributing elements, is a significant impact under CEQA, requiring mitigation. Without the Orchard, the Farmhouse alone would in all likelihood lose its eligibility for the National or California Registers because it would lack the ability to demonstrate a vital connection with the area's agricultural heritage. The Orchard demolition fails to comply with the Secretary 's Standards for multiple reasons. Under the National Register Bulletin entitled "Defining the Boundaries for National Register Properties," the entire Orchard parcel is included within the eligible site. The Orchard and Farmhouse were a single functional unit, in common ownership, on a single parcel and visually separate from surrounding uses. Under the Secretary 's Standard's, a building site consists of historic "buildings, structures, and associated landscape features within a designed or legally defined parcel of land." In this case, as recognized by the Council in its designation, the Orchard is significant in its own right, as well as in combination with the Farmhouse. The Secretary 's Guidelines for the Treatment of Cultural Landscapes requires consideration of continuity of form, use, features and materials. The geographic context of the landscape, including the component elements and features, are factors that affect the appropriate treatment. Natural systems are an integral part of the cultural landscape and must be considered in selecting an appropriate treatment. Although it is often impossible to preserve the entirety of a cultural landscape in an urban setting, enough of the landscape must be retained to maintain integrity and the ability to convey 4100 FOLSOM BLVD Units% SACRAMENTO, CA 95819 mwdonatdsonl3 @yahoo.com 916 532 8004