Attachment C - Memorandum.pdfDATE: February 5, 2019
TO: Etienne & Marie -Alice Guerard
10518 Phil Place
Cupertino, CA 95014
(via email)
MEMORANDUM
RE: Supplemental Secretary of the Interior's Standards Review
Revisions/Clarifications to Project at 10518 Phil Place, Cupertino, CA
FROM: Leslie A.G. Dill, Historic Architect
INTRODUCTION
This memorandum provides a brief addendum to our review of the design of residential
rehabilitation project at 10518 Phil Place, Cupertino, the Historic Miller House. The project has
recently been revised to include clarifying window schedule and trim information. The review in
this memorandum was requested by the City of Cupertino and represents only new analysis that
addresses the revised portions of the project. This memorandum is intended to be used together
with our previous report.
The rehabilitation project was previously reviewed by Archives & Architecture LLC for consistency
with the Secretary of the Interior's Standards for the Treatment of Historic Properties (Standards) in
a report entitled "Secretary of The Interior's Standards Review: Proposed Rehabilitation Project at
the Historic Miller House" revised most recently on June 28, 2018. The overall composition of the
proposed project was reviewed, along with the project materials and details.
The current design being reviewed is dated January 15, 2019 and consists of twenty-four sheets. It
was prepared by Studio S Squared Architecture.
EXECUTIVE SUMMARY
The revised portions of the proposed project are compatible with Secretary of the Interior's
Standards for the Treatment of Historic Properties. The project, as presented, can be found to have
been mitigated to a less -than -significant impact under the California Environmental Quality Act.
REVISED PROJECT DESCRIPTION
The current project set continues to propose primarily interior reconfiguration of the plan,
accompanied by window and door alterations that affect the exterior. Some additional alteration of
exterior forms and detailing has been reviewed in the past.
The proposed project plans have been revised to include generalized notes about the significance of
the house, a comprehensive window and trim schedule, and photographic documentation of the
house, windows, doors, and trim.
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SUPPLEMENTAL SECRETARY OF THE INTERIOR'S STANDARDS REVIEW:
1. "A property will be used as it was historically or be given a new use that requires
minimal change to its distinctive materials, features, spaces, and spatial
relationships."
Analysis: The revised project does not propose to change the use of the historic residence.
The proposed project continues to be compatible with Standard 1.
2. "The historic character of a property shall be retained and preserved. The removal of
historic materials or alteration of features, spaces, and spatial relationships that
characterize a property will be avoided."
Analysis: The proposed window replacement scope was reviewed in previous reports, and
the revised project drawings clarify and better describe the previously understood
detailing, including the approach to each window and the proposed trim for altered
windows. The overall analysis does not change in this version of the proposal, and the
proposed project remains consistent with Standard 2.
3. "Each property will 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 historic properties, will not
be undertaken."
Analysis: The recent report concluded that, "The proposed new windows are designed to
be differentiated in a way that they would not be mistaken for original features. The new
windows are 1 -lite sash. No other elements are conjectural in association or would be
mistaken for historic features." No revisions have been made to this design. The project
remains consistent with Standard 3.
4. "Changes to a property that have acquired historic significance in their own right will
be retained and preserved."
Analysis: This supplemental review continues to analyze the project as though the
Craftsman features have acquired significance in their own right, although at a somewhat
lesser level of significance than the earlier, nineteenth-century elements. The previous
conclusions do not change with the clarifying information included in the revised design.
The project continues to be consistent with this Standard.
S. "Distinctive materials, features, finishes, and construction techniques or examples of
craftsmanship that characterize a property will be preserved."
Analysis: The primary features, finishes, and construction techniques or examples of
craftsmanship that characterize the Miller House are generally proposed for preservation in
this project. The revised drawings clarify this approach and the project remains compatible
with Standard 5.
6. "Deteriorated historic features will be repaired rather than replaced. Where the
severity of deterioration requires replacement of a distinctive feature, the new
feature will match the old in design, color, texture, and, where possible, materials.
Replacement of missing features will be substantiated by documentary and physical
evidence."
Analysis: A general note has been added to the revised cover sheet; it provides clear
direction about the review of treatment of the property during construction. The title pages
also have been revised to indicate that the property is considered a historic resource. If
A R C H 1 V E S & A R C H 1 T E C T U R E
unexpected repair of historic elements is found necessary during the construction process,
these notes direct the project to be reviewed prior to action and allow the element to be
repaired consistently with this Standard.
7. "Chemical or physical treatments, if appropriate, will be undertaken using the
gentlest means possible. Treatments that cause damage to historic materials will not
be used."
Analysis: No chemical or physical treatments were shown as proposed and none are
expected in this project, other than preparation for painting. The revised drawings remain
consistent with this Standard.
8. "Archeological resources will be protected and preserved in place. If such resources
must be disturbed, mitigation measures will be undertaken."
Analysis: Archeological resources are not reviewed in this report.
9. "New additions, exterior alterations or related new construction will not destroy
historic materials, features, and spatial relationships that characterize the property.
The new work shall be differentiated from the old and will be compatible with the
historic materials, features, size, scale and proportion, and massing to protect the
integrity of the property and its environment."
Analysis: The revised project drawings note and illustrate, in more detail than the original
plans, the specifications for the replacement windows and trim, along with the
specifications for new windows and trim. The analysis from the previous report remains
consistent with the new information in general.
In the window schedule, the design of the proposed trim notes that 1x6 flat -board trim will
be used at all the new window and door openings. There are currently four types of window
and door casings at the house, representing differing rehabilitation projects over time. The
proportions are all based on a nominal 6" (actual 5-1/2") board. Some are shaped; some
have architrave border trim. The proposed use of a plain flat -board trim is consistent with
preservation best practices because the proportions and scale will be similar, but the new
work will be differentiated by its simplicity.
The proposed project is compatible with Standard 9, as revised and clarified.
10. "New additions and adjacent or related new construction will 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."
Analysis: As analyzed in the previous report, the proposed design would preserve the
essential form and integrity of the historic property. The critical character -defining features
of the exterior of the house would be unimpaired in this project.
The proposed project remains in keeping with Standard 10.
CONCLUSION
The revised portions of the proposed project are compatible with Secretary of the Interior's
Standards for the Treatment of Historic Properties.
A R C H 1 V E S & A R C H 1 T E C T U R E