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® PLACEWORKS could create an additional 122 parking spaces on levels P1 through 8, raising the total on -site parking supply for the mixed -used project spaces from 196 to 318. In addition, the PIMP indicates that an additional 50 off -site parking spaces could be leased on a long-term basis at on -site or nearby City owned parking structures. When implemented, this would result in an effective parking ratio of 1.86 parking spaces per residential unitwith the on -site valet service, and 2. 15 spaces per unit with the additional 50 off site spaces, which would be equivalent to the 2.15 per unit parking space requirement of the TZC. The parking study supports the parking ratio of one space for every studio and one bedroom and two spaces for every two -bedroom unit for variety of factors. These include the project's proximity to existing and future mass transit, such as standard bus service, high -capacity/ express bus service, the Santa Ana Regional Transportation Center, and the under -construction OC Streetcar; the Project's location within a high amenity, mixed -use environment with shopping and major employment centers nearby; and proximity to nearby existing parking facilities, including parking structures, parking lots, and on -street parking. Finally, as noted above the Proposed Project is located in a Transit Priority Area (TPA) and therefore, aesthetic and parking impacts cannot be considered a significant impact. 0-6 The Commenter raises questions on the options to convertthe hotel to residential units and analysis of the conversion to residential. Per the Disposition and Development Agreement Sections 5.12.4 and 5.12.5 the applicant is entitled to submit an application to convert the hotel to apartments subject to meeting specific requirements and is subject to future review and approval. The conversion of the hotel to apartments will be subject to analysis under the California Environmental Quality Act and analyzed at the time that the application to convert is submitted, if an application is submitted. The Disposition and Development Agreement does not pre -commit or imply that the application to convert the hotel to apartments will be approved. The City retains the discretion to approve, conditionally approve or disapprove the application to convert the hotel to apartments. 0-7 The Commenter states there is no analysis of the impact on the historic properties in the area, including the Spurgeon building and no analysis of the requested incentives/concessions/waivers as it relates to the historic properties in the area. Section 5.5 of the Addendum analyzes the impacts to the historic properties in the area. The Project Site is adjacentto the Downtown National Register District and is not within the District. The District borders the Project Site to the north, east, and west. The closest historical resources include the properties along Broadway (across the streetfrom the Project Site), and along 4th Street (across the alleyway from the Project Site). While the adoption of the Transit Zoning Code (SD 84) allows the reuse, relocation, or demolition of designated or potentially historic structures, the existing 3-level parking garage constructed in 1982, located at 201 West 3rd Street, is not classified as a historic structure and exists on land that has already been disturbed. The Certified EIR determined that the adoption of the Transit Zoning Code (SD 84) could result in substantial adverse change in the significance of a historical resource as defined in Section 15064.5 of the CEQA Guidelines. Compliance with identified mitigation measures would reduce the magnitude of this impact, but the impact would remain significant and unavoidable. As described on page 104, the project's General Plan designation is District Center (DC), intended to be "developed with an urban character that includes a mixture of high-rise office, commercial, and residential uses." The Proposed Project is consistent with the land uses allowed within the Downtown DC. The Project proposes a residential density of approximately 121 dwelling units per acre. A density bonus of 35 percent grants an additional 45 units. However, per California 75A-478 November 2020 1 Page 5