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It is our opinion that the present condition of the grove does not provide a valid <br />representation of a typical historic orange growing operation. Old time growers would find such <br />a designation as ludicrous. <br />2. Contribution of Small, Family-based Citrus Operations. We do not dismiss the small, <br />family-based citrus growers as being important in the citrus industry. Our original farm of 25 <br />acres was a small family-based operation. We do not know the statistics of orange groves in <br />the northeast area of Santa Ana, but we doubt that there were any operations larger than 40 <br />acres; all were owned by families. The main characteristic for farms of about 5 acres is the lack <br />of onsite equipment and tools of production. These include barns to house horses or tractors <br />and the various cultivation tools such as, discs, harrows, and furrowing equipment. The small <br />farms would contract with neighbors or others for this work. <br />3. "Active Participation" of Landowner in Maintaining Historical Property. It is correct <br />that the Municipal Code does not require owner consent for designation to the Register of <br />Historical Properties. However, such a designation does have consequences. It would be a <br />dereliction to ignore these consequences. SOOC suggests that the city could use code <br />enforcement measures to ensure owner upkeep of the property. This in effect is to force the <br />owner to operate what essentially is a business and to engage in commerce. The entire historic <br />reason for having an orange grove was to engage in a profitable enterprise. No attempt has <br />been made to develop a cost analysis of how to restore and to operate this 5 acre area as a <br />productive orange grove. How would the fruit be processed and marketed? It seems highly <br />doubtful that any city or governmental agency has the power to force anyone to make annual <br />expenditures in a business venture that has virtually no prospect of having a market. It is fairly <br />obvious that the "Active Participation" and "willful neglect" factors were intended to apply to a <br />fixed structure such as a home or office building. These structures have relatively small annual <br />expenses. An orange grove of 430 trees has major annual expenses for irrigation water and <br />other costs without prospect of offsetting income. Irrigation water would come from the <br />domestic water system of the City of Santa Ana. Would irrigation water be cut off in event of a <br />water shortage? <br />4. Financial Impact of Historic Preservation of Property Valuation. No one has suggested <br />that the preservation of this property as an historic site can increase the market value of the <br />property. it should be obvious that such a designation makes it much more difficult for the <br />owner to pursue an alternative use of the property that provides a fair market value for the <br />property. It is understood that the counsel to the Historic Resources Commission indicated that <br />a land owner of property designated as historic could still convert the property to other uses. <br />The designation is recognized as being an impediment to processing the change. <br />It is instructive to review the "Save Our Orchard Coalition Mission and Goals" which are <br />available on the internet. The Goals are: <br />"1. Stop the proposed 24-unit housing development at our historic orchard. <br />2. Acquire the five-acre orchard from the current owners-Concordia University Irvine <br />and Orange Lutheran High School, Orange. <br />75B-29