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�s g <br />Page 3 <br />and retains an adequate amount of the historic resource must be the approved Alternative; it <br />simply must be in the EIR document. <br />Lastly, there have been two Technical Memoranda prepared by URS, Inc. for this EIR. One was <br />prepared on October 10, 2012 for the Hybrid Development Alternative (10% Alternative) and <br />the other on November 22, 2013 for the Historic Preservation Alternative (5% Alternative). If you <br />read the findings of these two memos side -by -side you will see the apparent logical <br />inconsistencies in the "analysis" of the 5% Alternative. These inconsistencies lead me to <br />believe that there is a lack of understanding, or knowledge, regarding the importance of <br />significance and integrity as they relate to historic resources and an equal lack of <br />understanding, or knowledge, as to how to follow CEQA guidelines where preservation and <br />mitigation are concerned. As you read through the opening paragraphs of each of these <br />documents and the Background, Description of the Historical Resource, and Significance of the <br />Historical Resource sections, you will find that most of the wording is exactly the same. The <br />Impacts sections for each Alternative are somewhat different. <br />Using NIPS publications, including Fruitful Legacy, the consultants refer to the 13 landscape <br />characteristics that specifically apply to orchards as historical resources. Of the thirteen <br />characteristics: one is not applicable to this resource; one is not currently retained at this <br />resource; in the 10% Alternative, three of the landscape characteristics will be "retained" and six <br />will be "lost "; in the 5% Alternative, seven will be "retained" and three will be "impaired." It is <br />easy to see the contradictory issues when the Alternatives are compared in the table below: <br />Landsca e <br />r< sr o <br />10 fo Alternative <br />� �� Y r a �, � x <br />rmrr o x, , <br />5 /o Alte(natroe <br />,,� , �r, � u se„ �2 <br />Charact ristic <br />: k <br />,r a a a�ybaa��, <br />on), <br />Historc Prsa {ion)r <br />kk rp; <br />with..10 <br />Natural Systems & <br />Retained: <br />Retained: <br />Features <br />".., the Natural Systems and Features of <br />"... the Natural Systems and Features of the <br />the land itself would not be lost, ..." it <br />land itself would not be lost, ... it would not <br />would not "likely be recognizable as what <br />"likely be recognizable as what exists <br />exists currently." <br />currently." <br />Spatial <br />Lost: <br />Impaired: <br />Organization <br />"As most of the trees would be <br />`... Spatial Organization would be lost." <br />demolished, and the house moved ..., the <br />Spatial Organization would be lost." <br />Land Use <br />Lost: <br />Retained: <br />"The Land Use would transition from a <br />"The property would retain its Land Use as <br />historic single- family residence with <br />a small -scale orchard and residence, <br />agricultural improvements to a suburban <br />although the orchard space would be much <br />development ..., with very few of the <br />smaller." <br />extant orange trees to remain." <br />Cultural Traditions <br />Lost: <br />Retained: <br />"The Cultural Traditions of the orchard <br />"The Cultural Tradition of growing ... <br />would be completely lost." <br />orange trees ... will be retained; ..., fewer <br />trees would be in the orchard." <br />Circulation <br />Lost: <br />Retained: <br />"... Also changed would be the <br />"Some of the Circulation network located <br />Circulation of the lot." <br />between the existing trees would be <br />retained; however, a large portion of the <br />network would be lost by the new <br />develo meat ..." <br />75A -177 <br />