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Page 2 <br />property establishes a precedent for the city of Santa Ana. This understanding is <br />reaffirmed in the Technical Memorandum describing the HPA when it states, "... the <br />Sexlinaer orchard [emphasis ours] is considered a historic resource under the SARHP <br />for the purposes of CEQA." <br />The consultant's understanding and use of various National Park Service publications <br />and the Secretary of the Interior's Standards for the Treatment of Historic Properties <br />(Secretary's Standards) is the basis for their arguments that reduce the designated <br />historic property from five acres to 10,044 square feet. That their proposals of the <br />restoration of the structures and the retention of a few orange trees can be considered <br />adequate mitigation of recognized adverse impacts "to a level of less than significant <br />impact on the historic resource" is without merit. <br />The HPA lists a series of the rehabilitation standards put forth by the Secretary's <br />Standards, some of which the Conservancy believes do nothing to address the impacts <br />of the essential demolition and destruction of the orchard itself and others which, based <br />on the description of how this alternative will be implemented, will not occur at all. <br />Example: "A property will be used as it was historically." Based on the detailed <br />description of this alternative, the use of the property will be as a standard residential <br />property without any reference to use in it's true historical context, that of a family farm <br />complex. Remember, this property is an original five acre, family owned, commercial <br />orchard, not a remnant. <br />The HPA invokes CEQA guidelines from the standpoint of defining substantial adverse <br />change in the significance of a historical resource. They sight "substantial adverse <br />change" as the "demolition, destruction, relocation, or alteration activities that would <br />impair the significance of the historic resource." Examples of adverse impacts <br />acknowledged in the HPA include "... a large portion of the [orchard] network would be <br />lost" and that under the HPA the "natural systems and features" of the land would not be <br />"recognizable as what exists currently." Additionally, the "overall setting and relationship <br />with the landscape would be impaired by the construction of additional residences." It is <br />acknowledged that the HPA would result in the loss of the spatial organization of the <br />historic site and the "extant landscape would undergo significant change as the vast <br />majority of the orange trees of the project site would be removed." Given these <br />expected impacts of the proposed project we see no way that the HPA can retain the <br />historical integrity, significance and overall character of the historic resource. The <br />remaining 10,000 square feet will, in our view, not adequately convey the scope of the <br />historical Sexlinger Farmhouse and Orchard. Furthermore, the Conservancy cannot, in <br />anyway, consider this proposed alternative as being a mitigation plan which will reduce <br />adverse impacts to a "level less than significant." <br />We feel that our proposed 50/50 development /preservation alternative is much more in <br />keeping with the true intent of the Secretary's Standards by allowing enough acreage to <br />retain the historical integrity of the "property's location, feeling, and overall character." <br />www.01dOrchardConservancy.or <br />75A -61 <br />