80A - SUPPLEMENTAL - SANTA ANA TRANSITZONINGCODE POST- RESPONSE TO COMMENTS - FEIR

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Chapter 12 Responses to Comments Received Since Publication of the Final EIR City of Del Mar P. City of San Diego [1982] 133 Cal.App.3d 401) Refer to the City /Agency's Findings on Mitigation Measures Proposed to Reduce Impacts to Cultural Resources in the Findings of Fact and Statement of Overriding Considerations for a further discussion. Response to Comment BHLG -5 This comment appears to reference Figure 5 -1 (Demolitions) contained on p. 5 -6 of the Recirculated Chapter 5 (Alternatives) of the EIR. The comment states that "at least 10" of the structures identified in Figure 5 -1 should be rehabilitated in place, if feasible, or moved within the Lacy Neighborhood. The comment does not specify which structures should be rehabilitated or moved. Note that there are a very limited number of designated historic resources in the Lacy Neighborhood (see Draft EIR Figure 4.4 -1 [Santa Ana Register of Historical Properties within the Transit Zoning Code Area]), and the neighborhood itself has not been designated as historic. Additionally, mitigation measure MM4.4 -3 would reduce impacts to historic resources throughout the Transit Zoning Code Area to the extent feasible. Preservation of ten of the existing structures proposed for demolition in the Lacy Neighborhood is not feasible because it will inhibit the City's ability to meet its affordable housing goals. Construction of affordable housing units is critical to meeting the City's Regional Housing Needs Assessment (RHNA) for 2006 -2014, and the City has an adopted policy to "maximize affordable housing on Agency -owned properties that is of high quality, sustainable, and available to various income levels." (Refer to Santa Ana Housing Element [2006- 2014], Policy HE -2.8.) Additionally, preservation of certain properties within the Lacy Neighborhood may inhibit the City's ability to "encourage the construction of rental housing for Santa Ana's residents and workforce, including a commitment to very low, low and moderate income residents and moderate income Santa Ana workers" (Policy HE -2.3) and to fulfill its policy to "facilitate and encourage a diversity and range in types, prices, and sizes of housing, including single - family homes, apartments, town homes, mixed /multiuse housing, transit- oriented developments, and live /work housing" (Policy HE -2.4). (Refer to Santa Ana Housing Element [2006- 2014].) Further, preservation of all of ten of the existing structures proposed for demolition in the Lacy Neighborhood would be inconsistent with the primary objectives of the proposed Developer Project to "redevelop all of the Agency -owned properties" and "provide new affordable housing for families in furtherance of the City's affordable housing goals established in the Housing Element, the Implementation Plan for the Santa Ana Merged Redevelopment Project Area, and the City of Santa Ana Consolidated Plan." The infeasibility of Alternatives 4, 5 and 6 is discussed in the City /Agency's Findings Regarding Project Alternatives in the Findings of Fact and Statement of Overriding Considerations. Response to Comment BHLG -6 It is unclear from this comment what is meant by the properties not having been "inspected." All of the properties currently owned by the Redevelopment Agency have been inspected numerous times to determine their safety and suitability, as well as to allow for the salvage of architectural details by volunteer groups. Most recently the properties were inspected for purposes of determining estimated rehabilitation costs that were used in Appendix J, the Keyser Marston Analysis, which analyzed the economic feasibility of Alternatives 4, 5, and 6. Further, the properties identified for demolition on parcels currently owned by the Agency have been the subject of "windshield" surveys to determine their potential eligibility for listing as a historic resource. (Refer to Draft EIR Section 4.4 and Appendix D.) Specifically, in 2006, HRG conducted a reconnaissance -style survey and historic research project in City of Santa Ana Transit Zoning Code (SD 84A and SD 84B) EIR 12 -23