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PALMIERI HENNESSEY LEIFER, LLP Honorable Mayor and City Councilmembers of the City of Santa Ana October 20, 2020 Page 4 There are significant impacts to the adiacent redeveloped historic properties such as the Spurgeon Building as a result of the proposed height, massing, floor area ratio and parking waivers/concessions: The Project proposes significant waivers/concessions to deviate from the development standards which were analyzed and approved in the 2010 FIR. Indeed, in its analysis of the impact of the Transit Zoning Code on historic sites, the 2010 FIR provided that the design and development standards contained within the Transit Zoning Code "contain detailed requirements in regards to building types, frontage types, massing, height, architecture, accessibility, parking, street presence and landscaping. These standards are specifically designed to ensure that new development within established neighborhoods, as well as existing commercial areas, is sensitive to the existing built form of that area." (2010 EIR, Sec. 4.4, p. 4.4-17 [emphasis added].) Specific to this area, the 2010 FIR states, "The DT Zone creates a cohesive and consistent set of requirements to ensure that any new projects developed within the Zone adhere to a unified set of standards, thereby ensuring that all new development within the Historic Downtown is considered within the same context as opposed to having a patchwork of standalone zones. Specifically, the DT Zone limits building heights based upon the existing historic context of the buildings currently located in the Historic Downtown." (Id. at p. 4.4- 18 [emphasis added].) Even with those "detailed requirements" and design/development standards, the 2010 FIR concluded the Transit Zoning Code would cause a substantial adverse change in the significance of historical resources and that such effects were significant and unavoidable. (See Id. at p. 4.4-22.) Now, a decade later, with proposed development at the rear frontage of one of the most historic street frontages in Santa Ana including the Spurgeon Building the City seeks to dispose or ignore the very standards it imposed. Height ignored. Massing more is more. Floor Area Ratio let's get the numerator to be as high as possible. The conduct goes even further as it completely omits any analysis that such deviations would have on the redeveloped historic sites like the Spurgeon Building. The proposed Project proposes a height 150 percent taller than the height limit imposed a decade ago. Essentially, no standards are applied if a building can be constructed half again taller than the limit. The proposed Wilshire Blvd. -type Project absolutely dwarfs the historic surroundings. The height limit was adopted and imposed for a reason because a 16-story building within the historic downtown area of Santa Ana is not in keeping with the character of the area. The height will have a negative impact on the historic and redeveloped Spurgeon Building its clocktower and its companion properties Here is an obvious question, what