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Chapter 3 F/nd/ngs Regarding Protect Alternatives <br />merely clarify and amplify the analysis presented in the EIR and do not trigger the need to recirculate per <br />CEQA Guidelines ~15088.5(b). <br />~ Findings on Measures Suggested in Comments on the Draft EIR <br />Several mitigation measures and alternatives were proposed in public comments on the Draft EIR. <br />Findings fox these mitigation measures and alternatives are provided below- <br />Findings on Mitigation Measures Proposed to Reduce /mpacts to Cuitura/ Resources <br />~ Proposed Mitigation Measure. Make the Lacy Neighborhood a special district based on its <br />histarical character and proposed a Historic Neighborhood District, Conservation or Preservation <br />Overlay for the Lacy Neighborhood. (See Final EIR Chapter 3 (Responses to Comments), Letter <br />from Jeff Dickman (JD), comments JD-24, -27, -35, and -45.) <br />Finding. The Agency Fmds that specific economic, legal, social, technological, or other <br />considerations make this mitigation measure infeasible. <br />Rationale. The Lacy neighborhood has not been designated as historic, and there is no evidence <br />that the creation of a historic district within the Lacy Neighborhood would reduce the significant <br />impacts of the proposed project. Further, the creation of a historic district within the City is a <br />separate process requiring adoption of a local preservation ordinance and cannot be accomplished <br />through the CEQA process for the proposed project. (See Santa Ana Municipal Code, Part II, <br />Chapter 30.) Therefore, it is not feasible to adopt and implement this measure as part of the <br />project. <br />~ Proposed Mitigation Measure. Create a "Master Plan for the Preservation of Cultural Resources <br />in the Transit Zoning Code Area" that identifies properties expected to be impacted by the project, <br />the type of impact expected, and mitigation measures to reduce impacts to and avoid demolition of <br />historic properties. (See Final EIR Chapter 3 (Responses to Comments), Letter from Jeff Dickman <br />QD), comment JD-26.) <br />Finding. The Agency Fmds that specific economic, legal, social, technological, or other <br />considerations make this mitigation measure infeasible. <br />Rationale. Identification of the properties that would be impacted by the project, identification of <br />the type of impact expected, and identification of mitigation measures to reduce impacts and avoid <br />demolition of historic properties has already been conducted in the EIR. Specifically, Table 4.4-2 <br />(as modified in Final EIR Chapter 2) lists all properties proposed for demolition under the <br />proposed Developer Project, and the analysis under Impact 4.4-3 explains that multiple studies <br />have been completed that address many of the historic-age properties within the project area. In <br />2006, HRG conducted areconnaissance-style survey and historic research project in support of the <br />Santa Ana Renaissance Specific Plan prepared by Moule 8c Polyzoides (HRG 2006). This project <br />aimed to provide recommendations for historic preservation planiii:ig on about 400 acres, <br />including many of the properties found within the Transit Zoning Code (SD 84A and SD 84B) <br />project area. Subsequent property-specific studies were conducted by Jones and Stokes (2006 and <br />2007), which resulted in the full recordation and evaluation of many of the properties within the <br />Transit Zoning Code (SD 84A and SD 84B) project area. These evaluations included <br />determinations of eligibility for the NRHP, CRHR, and the Santa Ana Register of Historic <br />Properties (SARHP). An additional historic resources memorandum for the record was then <br />prepared for several properties in Santa Ana by Sapphos Environmental, Inc. This memorandum <br />provided recommendations about the eligibility of 30 properties for inclusion in the SARHP. <br />3-16 Transit Zoning Code (SD 84) EIR Findings of Fact/Statement of Overriding Considerations <br />