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• • • 1 �1 " 1 FBI <br />City of Santa Ana Planning Department <br />August 21, 2013 <br />Page 2 <br />Section 51201 defines "prime agricultural land" to include land with prime soils and orchards <br />that normally produce more than $200 per acre. Although the Sexlinger Orchard was removed <br />from production by its current owners, it contains unusually high - quality soils and produced <br />citrus at economic levels for more than a century. See Section 51201 (copy attached) and <br />Stivers Report (previously submitted). <br />Under Masonite, "standard" mitigation for loss of the highly productive Sexlinger Orchard would <br />be an agricultural conservation easement over 2.5 acres on -site or 5 acres off -site. The <br />remaining 2.5 acres of the Orchard would be available for compatible residential development, <br />as proposed in 1 of the alternatives identified by the Conservancy. Evidence collected by the <br />Conservancy demonstrates that continued use of the Sexlinger Orchard for citrus production is <br />possible due to its high - quality soils, making agricultural use both legally and economically <br />feasible. <br />Masonite also clarifies the City's obligation to adopt conditions that avoid or reduce impacts to <br />the Farmhouse and Orchard as mitigation for impacts to these historic resources. Preservation <br />of the designated resources in their original configuration is legally feasible and must be <br />required of the developer, unless it is shown to be economically infeasible. In this case, the <br />property has significant economic value with retention of both the Farmhouse and the Orchard, <br />requiring their preservation under CEQA. <br />The Conservancy looks forward to meeting with you to outline the alternatives they have <br />identified and to discuss any other questions you may have about their commitment to <br />preservation of the Sexlinger Farmhouse and Orchard. <br />Very truly yours, <br />Z f/ <br />Borah M. Rosenthal AICP <br />for SHEPPARD, MULLIN, RICHTER & HAMPTON LP <br />SMRH:409959605.1 <br />Enclosures <br />cc: Ms. Jeannie Gillett <br />Sonia Carvalho, Esq. <br />Ryan Hodge, Esq. <br />Mr. Robert Odle <br />Mr. Steve Ray <br />Mr. Nick Spain <br />75A -62 <br />