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Santa Ana General Plan Update <br />CEQA Findings of Fact and Statement <br />Of Overriding Considerations -45- October 2021 <br />2. Cultural Resources <br />Impact 5.4-1: Buildout consistent with the General Plan Update could impact an identified <br />historic resource. <br />Support for this environmental impact conclusion is fully discussed in Section 5.4, Cultural <br />Resources, starting on page 5.4-26 of the Updated Draft PEIR. <br />Generally, potential impacts to historical resources resulting from future projects developed <br />pursuant to the GPU would be mitigated by the City’s fulfillment of its statutory responsibilities <br />under CEQA. However, for certain development pursuant to the GPU, the City may determine <br />that significant impacts to historical resources cannot be avoided. The City shall require, at a <br />minimum, that the affected historical resources be thoroughly documented before issuance of any <br />permits. Though the possible demolition or alteration of a historical resource cannot be mitigated <br />to a less than significant level, recordation of the resource will reduce significant adverse impacts <br />to historical resources to the maximum extent feasible. <br />With fulfillment of the CUL-1 and CUL-2, future development consistent with the GPU would result <br />in a less than significant impact to cultural resources. However, if significant impacts cannot be <br />avoided, the City shall require, at a minimum, that the affected historical resources are <br />documented consistent with Mitigation Measure CUL-3. The Historical Resources Technical <br />Report determined that unavoidable impacts to historical resources resulting from future <br />development under the GPU will be reduced to the maximum extent feasible but will still be <br />significant with implementation of Mitigation Measure CUL-3. Therefore, the development under <br />the GPU would result in significant and unavoidable impacts. <br />Mitigation Measures <br />CUL-1 Identification of Historical Resources and Potential Project Impacts. For <br />structures 45 years or older, a Historical Resources Assessment (HRA) shall be <br />prepared by an architectural historian or historian meeting the Secretary of the <br />Interior’s Professional Qualification Standards. The HRA shall include: definition of a <br />study area or area of potential effect, which will encompass the affected property and <br />may include surrounding properties or historic district(s); an intensive level survey of <br />the study area to identify and evaluate under federal, State, and local criteria <br />significance historical resources that might be directly or indirectly affected by the <br />proposed project; and an assessment of project impacts. The HRA shall satisfy federal <br />and State guidelines for the identification, evaluation, and recordation of historical <br />resources. An HRA is not required if an existing historic resources survey and <br />evaluation of the property is available; however, if the existing survey and evaluation <br />is more than five years old, it shall be updated. <br />CUL-2 Use of the Secretary of the Interior’s Standards. The Secretary of the Interior’s <br />Standards for the Treatment of Historic Properties shall be used to the maximum <br />extent practicable to ensure that projects involving the relocation, conversion,