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 creation of new public open space, the elimination of blight, and an enhancement of the streetscape, would not be realized. Response to Comment BHLG -9 The comment appears to infer that relocating rehabilitated structures to 5`t' and 6`h Streets within the Lacy Neighborhood would serve to mitigate impacts to historic resources. Whereas there are a number of designated Historic Districts within the City, 5`h and 6`h Streets within the Lacy neighborhood have not been designated as historic, and there is no evidence that the creation of a historic district within the Lacy Neighborhood would reduce the significant impacts of the proposed project. Further, the creation of a historic district within the City is a separate process requiring adoption of a local preservation ordinance and cannot be accomplished through the CEQA process for the proposed project. (Refer to Santa Ana Municipal Code, Part II, Chapter 30.) Therefore, it is not feasible to adopt and implement this measure as part of the project. Refer to Response to Letter JD: Jeff Dickman, Response to Comment JD -1 for further explanation, and to Findings on Mitigation Measures Proposed to Reduce Impacts to Cultural Resources, p. 3 -16 in Findings of Fact and Statement of Overriding Considerations. Response to Comment BHLG -10 This comment is not a direct comment on environmental issues or the content or adequacy of the Draft EIR. The comment will be forwarded to the decision makers for their consideration prior to approval or denial of the proposed project. No further response is required. Response to Comment BHLG -11 Within the Lacy neighborhood, there are a limited number of designated historical resources, only one of which would be demolished under the proposed Developer Project (501 E. Fifth Street) (refer to Recirculated EIR, Figure 5 -1). An additional property eligible for listing on the California Register of Historic Resources (CRHR) (615 E. Fifth Street) would also be demolished under the proposed project. Refer to Response to Letter JD: Jeff Dickman, Response to Comment JD -1 for further explanation. Response to Comment BHLG -12 The comment states that implementation of the proposed project would result in the loss of "resources," which appears to be a reference to historic resources. As stated in Response to Comment BHLG -11, there are a limited number of designated historical resources existing within the project area. The comment requests that the City "consider the feasible rehabilitation of only a third" of the properties identified in the comment as subject to demolition by the proposed project, which is identified as 60. Although it is unclear what this number refers to and specific properties are not identified, this comment appears to suggest an alternative that conforms to the parameters described in Alternatives 4 and 5. The comment states that such an alternative would be "feasible" as it accomplishes "most of the project objectives." A full analysis of the feasibility of each of the Alternatives to the Developer Project has been provided in the Findings of Fact and Statement of Overriding Considerations, as well as in Appendix J — Keyser Marston Analysis. Each of the Alternatives analyzed was found to be infeasible for specific economic, legal, social, or other considerations, including their inability to meet the project objectives, as well as their inability to significantly reduce environmental impacts. Refer to the Findings of Fact and City of Santa Ana Transit Zoning Code (SD 84A and SD 84B) EIR 12 -25