4 - SPR19-01; DBA 19-01_114 117 E 5TH STREET COMMENTS

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“As board chairman at the Bowers Museum of Cultural Art in Santa Ana, he was instrumental in negotiating partnerships with the Smithsonian Institution and the British Museum, greatly expanding the museum’s offerings to the public. His support for a major addition — the Dorothy and Donald Kennedy Wing — tripled the Bowers’ exhibit space.” Based on the Survey's own findings, the extraordinary lives of the Parker and Kennedy families, one must conclude that the Orange County Title building, is likely eligible for inclusion to the City of Santa Ana's Register of Historic Properties, and similarly eligible for inclusion to the National Register of Historical Places, based on the building's association as a “center for political, social, economic, or cultural activity.” Other important concerns involve the inadequacy of the City's Transit Zoning Code EIR, and how it negatively impacts the examination and preservation of the Orange County Title building. Some of these defects are listed below. The Cultural Resources portion of the The Transit Zoning Code EIR (TZC) fails to discuss the First American Title building, even though this complex of buildings is within the boundary of the TZC. Table 4.4-1 of the TZC identifies numerous historic buildings in the Transit Zoning Code area. However the First American Title building is not on that list. The First American Title complex of buildings, nor the Orange County Title building specifically, was ever studied at a building level of examination, as part of the TZC EIR. This means the City has no information to provide the Planning Commission regarding the condition of the Orange County Title building, the two adjoining buildings, or any other clad structures within the larger city block of buildings. On page 4.4-11 of the TZC, “Unless a resource listed in a survey has been demolished, lost substantial integrity, or there is a preponderance of evidence indicating that it is otherwise not eligible for listing, a lead agency should consider the resource to be potentially eligible for the CRHR.” There is NO preponderance of evidence indicating that the Orange County Title building, or any other clad building within the First American complex of buildings, is not existing, and eligible. As such the City of Santa Ana must recognize the 1931 Orange County Title building, and any other clad building in the First American block, IS potentially eligible for the CRHR.  When the Transit Zoning Code was adopted in 2010, the City found there were no available mitigations measures to reduce impacts to less than significance – this is not true. Incorporating older buildings into the design of new buildings is a feasible mitigation measure that was not considered in 2010 or in the RINCON addendum. The information before the Planning Commission is defective and lacking.