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Chapter 3 Findings Regarding Project Alternatives <br />3.4.4 Additional Findings <br />¦ Findings Related to Clarifications and Updates to the Draft EIR <br />Chapter 3 of the Final EIR includes the comments received on the Draft EIR and responses to those <br />comments. The focus of the responses to comments is on the disposition of significant environmental <br />issues as raised in the comments, as specified by CEQA Guidelines ? 15088(b). Additionally, as a result <br />of refinements to the proposed Developer Project since publication of the Draft EIR, the allocation of <br />rental of units and for sale units that would be constructed under the proposed Developer Project and <br />under Alternatives 4, 5 and 6 has been slightly modified. The February 23, 2010 financial analysis <br />prepared by Keyser Marston Associates that was included as Appendix J to the EIR has been updated to <br />reflect these modifications. The updated financial analysis, dated May 22, 2010, is included as Appendix J <br />to the Final EIR. <br />Findings <br />Responses to comments made on the Draft EIR and revisions to the Final EIR merely clarify and <br />amplify the analysis presented in the EIR and do not trigger the need to recirculate per CEQA Guide- <br />lines ?15088.5(b). Similarly, the refined reallocation of rental and for sale residential units that would be <br />provided by the Developer Project and the updates to the Keyser Marston Associates financial analysis <br />merely clarify and amplify the analysis presented in the EIR and do not trigger the need to recirculate per <br />CEQA Guidelines ?I5088.5(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 for these mitigation measures and alternatives are provided below. <br />Findings on Mitigation Measures Proposed to Reduce Impacts to Cultural Resources <br />¦ Proposed Mitigation Measure. Make the Lacy Neighborhood a special district based on its <br />historical 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 UD), comments JD-24, -27, -35, and -45.) <br />Finding. The Agency finds 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 />3-16 Revised Station District Project and FOL Settlement Agreement Findings of Fact/Statement of Overriding <br />Considerations