75A - PH - EIR 1584 E SANTA CLARA AVE

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ORANGE LUTHERAN HIGH SCHOOL'S AND CONCORDIA UNIVERSITY'S MEMORANDUM IN RESPONSE TO COMMENTS ON PROPOSED DEVELOPMENT PROJECT AT 1584 EAST SANTA CLARA AVENUE 1. Introduction. During the public comment and hearing process on this project, the Planning Commission and City staff have received comments from the public that addressed the sufficiency of (1) the Environmental Impact Report (E1R), (2) the proposed variance findings for Lots 7 and 13 of the proposed project, and (3) the General Plan consistency findings for the proposed tentative tract map. City staff has responded to these issues by commissioning an additional environmental analysis ( "Additional Analysis ") that, among other things, examines the viability of a new Historical Preservation Alternative. Based on the Additional Analysis' conclusions, Orange Lutheran High School and Concordia University (collectively, the "applicant") have proposed significant revisions to its development proposal that effectively seek to implement the Historic Preservation Alternative. This memorandum explains how those revisions respond to and meaningfully address the most frequently recurring issues and concerns raised during the public review process. 2. The City Has Complied With Its General Plan Policy To "Encouragge the Retention and Reuse of Historical Buildings." In comment letters the City received on December 17, 2012 and on February 11, 2013, The Old Orchard Conservancy asserted that the FIR found a "clear conflict" with the General Plan Land Use Element Policy 4.2, which states that the City should "Encourage the retention and reuse of historical buildings and sites." This asserted conflict was raised as a challenge to both the sufficiency of the land use analysis in the EIR and the General Plan consistency findings for the tentative tract map. As discussed below, the project does not conflict with the General Plan because (1) the City has actively and thoroughly encouraged the retention and reuse of the historic resources on the project site, (2) the proposed project has been revised to include preservation of the farmhouse building, together with orchard trees, on -site, and (3) based on the foregoing, the City's draft FIR concludes that development in the manner now proposed by the applicant will not result in significant impacts to historic resources. The Land Use Element of the General Plan includes the following land use goal: "Protect and enhance development sites and districts which are unique community assets that enhance the quality of life." To advance that goal, the City established Land Use Element Policy 4.2 as follows: "Encourage the retention and reuse of historical buildings and sites." Consistent with both Land Use Element Goal 4 and Land Use Policy 4.2, the City created a comprehensive Historic Preservation Ordinance that defines the processes and means by which the City encourages the retention and reuse of historical buildings and sites. (Santa Ana Mun. Code ( "SAMC ") Ch. 30 [`Historic Preservation Ordinance "].) Those regulations have been applied to the Sexlinger Property. 75A -87