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Chapter 3 Findings Regarding Project Alternatives <br />historic properties. (See Final EIR Chapter 3 (Responses to Comments), Letter from Jeff Dickman <br />UD), comment JD-26.) <br />Finding. The Agency finds that specific economic, legal, social, technological, or other <br />considerations make this mitigation measure infeasible. <br />Rationale. Identification of the properties that would be impacted by the project, identification of <br />the type of impact expected, and identification of mitigation measures to reduce impacts and avoid <br />demolition of historic properties has already been conducted in the EIR. Specifically, Table 4.4-2 <br />(as modified in Final EIR Chapter 2) lists all properties proposed for demolition under the <br />proposed Developer Project, and the analysis under Impact 4.4-3 explains that multiple studies <br />have been completed that address many of the historic-age properties within the project area. In <br />2006, HRG conducted a reconnaissance-style survey and historic research project in support of the <br />Santa Ana Renaissance Specific Plan prepared by Moule & Polyzoides (HRG 2006). This project <br />aimed to provide recommendations for historic preservation planning on about 400 acres, <br />including many of the properties found within the Transit Zoning Code (SD 84) project area. <br />Subsequent property-specific studies were conducted by Jones and Stokes (2006 and 2007), which <br />resulted in the full recordation and evaluation of many of the properties within the Transit Zoning <br />Code (SD 84) project area. These evaluations included determinations of eligibility for the NRHP, <br />CRHR, and the Santa Ana Register of Historic Properties (SARHP). An additional historic <br />resources memorandum for the record was then prepared for several properties in Santa Ana by <br />Sapphos Environmental, Inc. This memorandum provided recommendations about the eligibility <br />of 30 properties for inclusion in the SARHP. (Refer to DEIR, Appendix D.) Table 4.4-1 lists all <br />properties listed on the SARHP that could be impacted by the proposed Transit Zoning Code, and <br />Figure 4.4-1 shows all of these properties on a map of the Transit Zoning Code area and the <br />surrounding areas. <br />The EIR then identifies Mitigation Measure MM4.4-3 to reduce impacts to historic resources <br />throughout the Transit Zoning Code Area. This measure would require a qualified professional to <br />conduct site specific historical resource investigations for future developments within the project <br />area that would demolish or otherwise physically affect buildings or structures 50 years old or older <br />or affect their historic setting. <br />¦ Proposed Mitigation Measure. Preserve historic properties in the Lacy Neighborhood. (See <br />Final EIR Chapter 3 (Responses to Comments), Letter from Jeff Dickman UD), comment JD-28.) <br />Finding. The Agency finds that specific economic, legal, social, technological, or other <br />considerations make this mitigation measure infeasible. <br />Rationale. There are a very limited number of designated historic resources in the Lacy <br />Neighborhood (see Draft EIR Figure 4.4-1 [Santa Ana Register of Historical Properties within the <br />Transit Zoning Code Area]), and the neighborhood itself has not been designated as historic. <br />Mitigation measure MM4.4-3 would reduce impacts to historic resources throughout the Transit <br />Zoning Code Area to the extent feasible. Preservation of all historic properties in the Lacy <br />Neighborhood is not feasible because it may inhibit the City's ability to meet its affordable housing <br />goals. Construction of affordable housing units is critical to meeting the City's Regional Housing <br />Needs Assessment (RHNA) for 2006-2014, and the City has an adopted policy to "maximize <br />affordable housing on Agency-owned properties that is of high quality, sustainable, and available to <br />various income levels." (See Santa Ana Housing Element [2006-2014], Policy HE-2.8.) <br />Additionally, preservation of certain properties within the Lacy Neighborhood may inhibit the <br />City's ability to "encourage the construction of rental housing for Santa Ana's residents and <br />workforce, including a commitment to very low, low and moderate income residents and moderate <br />Transit Zoning Code (SD 84) EIR Findings of Fact/Statement of Overriding Considerations 3-17