The Design of the New Annex and Compliance with The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Rehabilitating Historic Buildings

By Milford Wayne Donaldson FAIA
May 16, 2023

Architect Milford Wayne Donaldson FAIA Qualifications

Mr. Donaldson is president of award-winning Architect Milford Wayne Donaldson, FAIA, Inc. since 1978, specializing in historic preservation services. He is licensed to practice architecture in California, Nevada and Arizona and holds a certified license from the National Council of Architectural Registration Boards.  Mr. Donaldson is affiliated with several historical and preservation organizations and is a past president of the California Preservation Foundation
(CPF) and past chairs of the State Historical Building Safety Board and currently sits on the Board, the State Historical Resources Commission, and is a past member of the Historic State Capitol Commission.

Milford Wayne Donaldson served as the California State Historic Preservation Officer (CA SHPO) from 2004-2012. Mr. Donaldson was appointed and served as the Chair of the Advisory Council on Historic Preservation by President Barack Obama from 2010-2019.  

Over the last 45 years, Mr. Donaldson has established himself as a leader in Historic Preservation and adaptive reuse of existing structures. In 1991, The California Council of the American Institute of Architects acknowledged Mr. Donaldson for his statewide leadership in the interpretation of the California Historical Building Code that allowed the rehabilitation of historic buildings. In 1992, the American Institute of Architects inducted Mr. Donaldson into the College of Fellows, only 3% of licensed architects hold the title of FAIA.

Mr. Donaldson is very familiar with the historic California State Capitol and has commented as CA SHPO on several projects throughout his career as well as associated state buildings and Capitol Park. Milford Wayne Donaldson FAIA is qualified under the Secretary of the Interior’s Qualification Standards


The year 2016 marked the 50th anniversary of the passage of the National Historic Preservation Act on October 15, 1966. The Act increased the scope and responsibilities of the National Park Service regarding the preservation of cultural resources. The National Historic Preservation Act charges the National Park Service (through authority delegated by the Secretary of the Interior) to establish and administer a national historic preservation program and to develop and promulgate standards and guidelines for the treatment of historic properties.

The Secretary of the Interior’s Standards for Historic Preservation Projects were first issued in 1978. In 1979 they were published with Guidelines for Applying the Standards and reprinted in 1985. The Standards were revised in 1992, when they were retitled The Secretary of the Interior’s Standards for the Treatment of Historic Properties.

The Standards were codified in the Federal Register in 1995, the same year that they were published with guidelines as The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring and Reconstructing Historic Buildings (Standards and Guidelines). These Standards and Guidelines provide a critical part of the framework of the national preservation program. They are widely used at the federal, state, and local levels to guide work on historic buildings, and they also have been adopted by Certified Local Governments and historic preservation commissions across the nation.

Under the California Environmental Quality Act (CEQA), a project that has been determined to conform with the Secretary of the Interior’s Standards for the Treatment of Historic Properties can generally be a project that will not cause a significant impact to a historic resource (14CCR Section 15126.4(b)(1)). In fact, in most cases if a project meets the Secretary of the Interior’s Standards for the Treatment of Historic Properties it can be considered categorically exempt from CEQA (14 CCR Section 15331).

In each of the four chapters of the Standards and Guidelines, the “Recommended” and “Not Recommended” treatments have been periodically updated and revised through-out to ensure that they continue to promote the best practices in preservation. Rehabilitation is defined as the act or process of making possible a compatible use for a property through repair, alterations, and additions while preserving those portions or features which convey its historical, cultural, or architectural values. The Rehabilitation Standards acknowledge the need to alter or add to a historic building to meet continuing or new uses while retaining the building’s historic character.

Analysis can only be made on four renderings of the proposed project, three exterior perspectives of the new Annex and the new Visitors Center Entryway at the west façade. After repeated asks for information to obtain Preliminary and Design Development Construction Documents showing the evolution of the design strategy as based on the High-Level Space Program (Annex Overview and Sequence Report) dated August 16, 2019 showing intended uses, square footage required, security and ADA issues, no construction documents were received.

Excerpts have been taken from the Standards & Guidelines and are shown in the Table below. Access to the site can be found at:

The following analysis identifies those major flaws in the new Annex design and compliance with the Standards & Guidelines.



The existing 1952 historic Annex designed by Alfred W. Eichler; the California State Architect (1925-1963) can easily be modified to accept program modifications by altering non-character defining interior spaces. To date there has not been an analysis made for an adaptive reuse of the historic Annex. Eichler’s architecture respects and honors the original design of the 1874 Capitol, now restored. The historic East Wing Annex does not compete with or overpower the Capitol’s iconic Dome. Eichler’s architecture anchors the iconic Tower Bridge and the Capitol with its iconic Dome. Today, the Tower Bridge and the Capitol are the symbols of Sacramento as the Capital City of California.  

Eichler’s architecture of the East Wing Annex complements the West Wing, allowing the Capitol Dome to remain preeminent. The Capitol is the most significant governmental landmark in California’s history. Its architectural integrity is as important as that of the United States Capitol––after which it was designed. The Capitol and Capitol Park have earned the highest designation at the city, state, and national levels for protection and historic preservation as architect Mark Hulbert has noted, “The California Capitol Building including the mid-20th century East Wing is indisputably the heart of the mile-long Capitol Historic District.”

The existing historic Capitol and 1952 Annex designed by Alfred W. Eichler. Photo by Mark Hulbert.
The existing historic Capitol and 1952 Annex designed by Alfred W. Eichler, looking west.

“The California State Capitol Complex is one of the state’s most prominent historic places, containing notable examples of architecture and landscape design and the shared memories of many historic events. The West Steps of the 1874 State Capitol building, with their view down the Capitol Mall to the Tower Bridge, are a particularly important site of civic protest, engagement, and celebration. The 1952 Annex is an early example of contextual design, compatible in form and detailing to the 1874 State Capitol, while also clearly reflecting its mid-century era of construction. Changes to these resources should be considered with the greatest care, inspired by the state’s legacy of restoration and stewardship of the 1874 State Capitol Building.” National Trust for Historic Preservation letter to Governor Newsom, March 7, 2023.


The new West Entrance for the Visitors Center covers the original Greek Revival architecture including the columns, capitals, cornice, doors, and other historic and significant features. The proposed West Entrance destroys the existing historic west steps, the west lawn, plaza, and the major entry to the Capitol. The West Plaza and Capitol Steps of the original restored Capitol – the site of innumerable marches, speeches, and celebrations —will be eliminated by a Visitor Center with a theme-park-style entrance.  

This existing historic entry is on the most significant main façade of the Capitol as it looks down Capitol Mall to West Sacramento across the iconic Tower Bridge, also designed by state architect Alfred W. Eichler.


The meeting and gathering area for large events is necessary to promote the democratic processes.

Proposed New Visitors Center at the Main West Entry eliminates public gathering on a large scale. It also provides a 280-foot ramp with high terraced sides not usable by the public for large events.



The new Annex disrespects and overshadows the iconic dome with its large size and reflective glass facade. It denigrates the most important historic governmental landmark in California. The new Annex is substantially over size for the existing historic Capitol and results in the diminution and loss of the historic character of the Capitol. The edges of the new Annex stick out beyond the footprint of the Capitol making the new Annex superior and overbearing to the Capitol.

The proposed new Annex greatly impacts the east, north and south elevations of the 1860-1874 Capitol by introducing a large reflective glass structure and the historic Greek Revival style of the historic Capitol. The new proposed Annex also is one story higher than the existing historic Annex and impacts the historic 1874 Capitol dome.

The new addition is significantly different in terms of materials (granite, concrete and stucco versus reflective glass), openings (no defined openings are visible compared to the window and doorway openings of the historic Capitol), the architectural rhythm of the colonnades, and the horizontal lines and the roofline that define the Capitol. The large glass façade is so foreign to the materials and openness of the historic Capitol that it is significantly different and incompatible. The large glass structure is not consistent with the architecture and stature of the original Capitol.

Proposed New Glass Annex
South Façade of the Proposed New Glass Annex Sticking Out Pass the Historic 1874 Capitol
West Entrance, Proposed New Glass Annex


The alternative design for the Annex is much less massive in scale, its footprint is similar but smaller and there are several compatible relationships to the Capitol’s solids and voids, materials, and colors.


Massing and Façade of Alternative Design for the Annex

The alternative design for the Annex is subordinate and secondary to the historic Capitol and is compatible in massing, scale, materials, relationship of solids to voids, and color. The alternative design uses the same forms, materials, and color range as the historic Capitol in a manner that does not duplicate it but distinguishes the addition from the original 1974 Capitol. The design aligns the rhythm and size of the window and door openings to those openings of the historic Capitol. The alternative Annex design incorporates a simple, recessed connection that gently separates the Annex visually from the historic Capitol. The alternative Annex design is distinguished by setting it back from the wall plane of the historic Capitol.

South Façade of the Capitol with Alternative Design for the Annex in Background

To achieve the maximum space for the new program demanded by the Legislature the alternative Annex design has kept the same square footage, double T design, the galleria, same floor connections, etc. and meets all (or most) of the project objectives of the proposed new annex. However, to not compete visually, the alternative Annex design maintains the same exterior color, pattern of windows, has simple lines as to not overpower the historic Capitol but compliments its 1874 design. The exterior of the alternative Annex design is made of durable materials meant to last, solid concrete and granite. In addition, the alternative Annex design is intended to be protective of its inhabitants and difficult to attack. It is a “one-building” design.


The Capitol View Protection Requirements, Sacramento Zoning 17.216.860 C-3 protects The State Capitol building and the surrounding grounds of Capitol Park by establishing height restrictions, setback requirements, and parking regulations for certain areas of the CBD located near the State Capitol building and Capitol Park. These regulations are designed to provide visual protection to and from the Capitol building and Capitol Park as well as setbacks.


West Entry California Capitol Alternative Design for the Annex

West Entry California Capitol Alternative Design for the Annex

Comparison of Cross Sections showing Spatial and View Requirements

The alternative design for the Annex is on the top and reduces the overall height by one story.


The project creates irreversible damage to the park and trees. Demolition of the existing Annex would include excavating out the existing underground parking, which would be removed. Note that because a detailed landscape plan has not yet been prepared for the visitor/welcome center portion of the project site. Within the City of Sacramento, it is generally expected that the impacts to each individual tree on public property be evaluated by a tree care expert, and the impacts to the individual trees be explicitly disclosed to the public prior to a public project being approved. It is generally expected that decision making bodies are provided with enough information to make an informed decision and provide affirmative consent when trees are being removed.  

The draft environmental impact report in its current form is overly general in its treatment of potential impacts to trees and does not provide enough detail regarding expected tree removal and tree impacts for the public or a decision maker to understand which individual trees would be impacted and the significance of the expected impacts.  

Therefore, several trees were identified to be suitable for transplanting have been demolished that were noted in the EIR to remain. The project has affected 150 trees so far, not the originally EIR estimated 133 trees.

150 Trees Targeted for Removal (Destruction) or Relocation (May Not Survive)

The national standard for tree preservation during construction is the American National Standards Institute (ANSI) A300 part 5 standards for Management of Trees and Shrubs During Site Planning, Site Development and Construction. Other relevant parts of the ANSI A300 standard for Tree, shrub, and Other Woody Plant Maintenance-Standard Practices are part 1 which deals with pruning, part 2 which deals with soil management, part 6 which deals with planting and transplanting, part 8 which deals with root management, and part 9 which deals with tree risk assessment. The International Society of Arboriculture publishes Best Management Practices that are intended to be companion publications to the ANSI A300 standards. Best Management Practices exist under the following titles: "Managing Trees During Construction," "Tree Inventories," "Tree Risk Assessment," "Root Management," "Soil Management for Urban Trees," and "Tree Pruning." Having an ISA Certified Arborist who is familiar with construction projects develop and oversee the implementation of a tree protection plan that is consistent with the ANSI A300 standards and recognized Best Management Practices for tree care activities will greatly reduce the likelihood of unnecessary tree removal or damage to trees on the site. The Joint Rules Committees and DGS are not following the ANSI A300 standards.


One of California’s most valuable tools for the preservation of historic resources is the California Historical Building Code (CHBC), which is defined in Sections 18950 to 18961 of Division 13, Part 2.7 of Health and Safety Code (H&SC). The CHBC is intended to save California’s architectural heritage like the State Capitol by recognizing the unique construction issues inherent in maintaining and adaptively reusing historic buildings. The CHBC provides alternative building regulations for permitting repairs, alterations, and additions necessary for the preservation, rehabilitation, relocation, related construction, change of use, or continued use of a “qualified historical building or structure.”  

The CHBC’s standards and regulations are intended to facilitate the rehabilitation or change of occupancy to preserve their original or restored elements and features, to encourage energy conservation and a cost-effective approach to preservation, and to provide for reasonable safety from fire, seismic forces or other hazards for occupants and users of such buildings, structures, and properties and to provide reasonable availability and usability by the physically disabled.

The statute incorporates the definition of “qualified historical building” in Health and Safety Code § 18955 to include buildings or locations “deemed of importance to the history, architecture or culture of an area by an appropriate local, state or federal governmental jurisdiction” and includes buildings on the National Register of Historic Places and California Register of Historical Resources, among others. State law also established the State Historic Building Commission to manage historic preservation of State buildings. As a historical building on the National Register of Historic Places, the Capitol and Annex, considered as one historic building is subject to the requirements of the CHBC. The heightened standards of the CHBC “are intended to facilitate the rehabilitation, restoration, or change of occupancy so as to preserve their original or restored architectural elements and features.”

The People of the State of California, through their elected representatives in the Legislature, have demonstrated repeatedly their desire that historically significant landmarks, including the Capitol Building, be preserved, and protected. By creating the Commission, and as further evidenced by the California Constitution, the special regulations contained within the California Historical Building Code, and its placement on state and national registers of historic places, the Capitol Building has been deemed to be of singular historical significance.


“We recognize that important programmatic and safety issues at the Capitol Complex need to be addressed. The challenges of hazardous materials, lack of accessibility, inefficient systems, and inadequate space are real, but also not uncommon among public buildings in California and across the country. The planning and decision-making for how to improve one of the state’s most prominent public building complexes should be a model for other government agencies to follow.”  National Trust for Historic Preservation letter to Governor Newsom, March 7, 2023.

In conclusion, rehabilitation of the East Wing under the California Historic Building Code (CHBC) appears feasible as well as equivalent to the rehabilitation of other such important mid-20th century historic buildings which are successfully carried out each year throughout California and throughout the nation. As the working location for seven decades of leadership, commencing in 1951 with Governor and future Chief Justice of the United States Earl Warren, countless historic actions have been taken in the offices of California Governors, Lieutenant Governors, and thousands of lawmakers. The East Wing – the historic Capitol Annex – exists today as the foremost example of mid-20th century California design. Its qualities integrate and complement the architecture of the 1860-1874 Capitol. Since 1869, when occupancy of the West Wing began, 30 of the 40 California governors have left their trace on California’s history within the halls of the original and restored Capitol and East Wing Annex, including California Governor and 40th President of the United States Ronald Reagan.

From a moral standpoint, it is shameless to continue construction by abolishing historic preservation standards that other entities must follow.  The Legislature should add least implement design and that is in keeping with Standards unlike the current proposed Glass Annex. The proposed visitor's entrance and destruction of the Annex would not only be a foolish and wanton act but could also signal the beginning of the end of serious preservation activity by the government in California.  

Architect Milford Wayne Donaldson FAIA