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features (criterion '.l), land use(ciiterion 3), cultural traditions (criterion 4), topography (criterion. <br />6), and buildings and structures (criterion &) are all characteristics that are retained in the Historic <br />Preservation Alternative. Of the remaining five factors, the Additional Analysis concludes that <br />circulation (criterion 5), cluster arrangements (criterion 9), would be partially retained, As to the <br />remaining three ;factors — spatial organization, vegetation, and views and vistas — the Additional <br />Analysis concludes as follows: <br />Spatial Organization: "The spatial relationship between the residence and garage, <br />orientation of the property, and the property's visual narrative of a small scale orchard <br />would also be retained." <br />• Vegetation; "There would be substantially fewer trees than what historically existed; <br />however, new trees would be planted in -kind to fill out the parcel and to replace any <br />dead or decaying trees. The new tees would match the existing type (Valencia, <br />grafted to lemon rootstock) ...." <br />• Views and Vistas: "Lastly, the views and vistas would transition from that of a <br />pastoral and historic small orange grove to that of new residential buildings and <br />roadways," <br />In sum, the Additional Analysis concludes that 9 of the 10 applicable criteria are at least partially <br />satisfied. We respectfully submit that the tenth factor— views and vistas — is also at least <br />partially satisfied, inasmuch as the farmhouse will not be relocated, will be rehabilitated per <br />Secretary of Interior standards, and will remain visible from the street. Orange trees near the <br />house will also remain visible. In this regard, the property "would retain many of its major <br />elements and still convey the significance of a property type that was once eommon and .is now a <br />rare surviving example in the City." (Additional Analysis, p. 7.) <br />Based on the above, the Additional Analysis both (a) concludes that the Historic <br />Preservation Alternative will. mitigate impacts to cultural resources to a less -than- significant <br />level, and (b) finds that the alternative is the environmentally superior alternative for CEQA <br />analysis purposes. Importantly, as compared to the Hybrid Development Alternative, the <br />Historic Preservation Alternative better mcets the City's objectives — particularly the goal of <br />adding to the City's stock of move -up housing — because it would allow for the development of <br />23 of the originally proposed 24 homes on the site. <br />The foregoing illustrates the extraordinary steps the City has taken in an effort to <br />minimize impacts to historic resources. These steps show, in compelling fashion, that the City <br />has proactively and thoroughly encouraged the retention and reuse of historic buildings and sites, <br />and therefore complied with both Land Use Element Goal 4 and Land Use Policy 4.2; <br />To highlight this conclusion, we respectfully request that the language in the Final EIR <br />that could be construed to suggest a conflict with Land Use Element Goal 4 and /or Land Use <br />Element Policy 4.2 be revised as follows. <br />• The text of Final EIR Section 4.3 (Page 56, first fall paragraph) should be modified as <br />follows: <br />-5- <br />75B -249 <br />