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l •` iN ' •i <br />Page 2 <br />Definition of the Historic Resource Having a clear understanding of what the historic <br />resource includes is essential to understanding the documents related to this project. I <br />have, repeatedly, heard staff and city officials mistakenly characterize the historic resource <br />as the Sexlinger family home. Nothing could be farther from the truth. The newly proposed <br />5% Alternative seems to have been developed with just this definition in mind. The resource <br />is the five -acre orchard which includes the Sexlinger family home. Both the orchard and <br />home have historic value and that value is all the more important because they coexist, <br />together as one. Take away one or the other, the orchard or the house, and the resource <br />loses its significance and integrity. In order for a property to be worthy of listing on a local, <br />state or federal historic register as an historic resource, it must have both "significance" and <br />"integrity" Significance has been established as the Sexlinger property meets the <br />requirement of being "fifty (50) or more years old and it is" a site that was "connected with a <br />business or use which was once common, but is now rare." (Santa Ana Municipal Code: Sec <br />30 -2) The consultants used the National Park System (NPS) publications when discussing <br />both the Hybrid Development Alternative (10% Alternative) and the Historic Preservation <br />Alternative (5% Alternative), so I will refer to NIPS definitions here. "The historic integrity of <br />an orchard ... is a measure of physical authenticity, conveyed by extant characteristics or <br />features that were present during the period of significance." (Dolan: 178) In other words, if <br />things still exist at the property that were in existence when the property was a significant <br />part of our history, then the property has integrity. Integrity includes seven aspects as <br />defined by the NIPS. Collectively, these seven aspects provide a measure of authenticity <br />and include location, design, setting, materials, workmanship, feeling and association. In <br />addition, there are "13 possible landscape characteristics that can be found in any cultural <br />landscape, including orchards. Not all 13 landscape characteristics are found in every <br />cultural landscape, and the characteristics are not mutually exclusive." (Dolan: 181) 1 do not <br />want to appear to be belaboring the point, but the concepts of significance and integrity are <br />extremely important to understand as you consider the information you have been provided <br />for this project and it's relevance for the approval or denial of the proposed Alternatives. <br />Next I would like to bring your attention to the EIR itself, specifically the requirement for a "range <br />of alternatives "as specified under the California Environmental Quality Act (CEQA). "Range of <br />alternatives" refers to different types of alternatives: i.e. a no -build option, the proposed project, <br />and another alternative that falls somewhere in between. Including additional alternatives that <br />accomplish the same outcome, no matter how many you have, does not provide a range of <br />alternatives. That could be defined as a /istof alternatives. Currently, the EIR includes two <br />types of alternatives, in other words, two lists. I will call them the "do- not - build- anything" list and <br />the " destroy- the - historic- resource - beyond- recognition" list. On the one hand, four of the <br />Alternatives call for no housing development, whatsoever, at the site; and, on the other hand, <br />the five remaining Alternatives call for most, if not all, of the destruction of this listed historic <br />resource. For example, the newest addition to the EIR, the 5% Alternative, can be added to the <br />" destroy- the - historic - resource - beyond- recognition" Alternatives list. Neither the "do- not- build- <br />anything" Alternatives nor the " destroy- the - historic - resource - beyond- recognition" Alternatives <br />satisfy the project objectives and retain the historic resource. It is a requirement of CEQA that <br />the EIR contain a "range of alternatives." Adding an Alternative that would retain enough of the <br />resource so that its significance and integrity remain intact, would satisfy the CEQA requirement <br />for a "range of alternatives." That is not to say that an Alternative that allows for development <br />• � r � is + <br />75A -176 <br />