75A - PH - EIR 1584 E SANTA CLARA AVE

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features (criterion 1), hand use (criterion 3), cultural traditions (criterion 4), topography (criterion 6), and buildings and structures (criterion 8) are all characteristics that are retained in the Historic Preservation Alternative. Of the remaining five factors, the Additional Analysis concludes that circulation (criterion 5), cluster arrangements (criterion 9), would be partially retained. As to the remaining three factors — spatial organization, vegetation, and views and vistas — the Additional Analysis concludes as follows: • Spatial Organization: "The spatial relationship between the residence and garage, orientation of the property, and the property's visual narrative of a small scale orchard would also be retained." Vegetation: "There would be substantially fewer trees than what historically existed; however, new trees would be planted in -kind to fill out the parcel and to replace any dead or decaying trees. The new trees would match the existing type (Valencia, grafted to lemon rootstock) ...." Views and Vistas: "Lastly, the views and vistas would transition from that of a pastoral and historic small orange grove to that of new residential buildings and roadways." In sum, the Additional Analysis concludes that 9 of the 10 applicable criteria are at least partially satisfied. We respectfully submit that the tenth factor — views and vistas — is also at least partially satisfied, inasmuch as the farmhouse will not be relocated, will be rehabilitated per Secretary of Interior standards, and will remain visible from the street. Orange trees near the house will also remain visible. In this regard, the property "would retain many of its major elements and still convey the significance of a property type that was once common and is now a rare surviving example in the City." (Additional Analysis, p. 7.) Based on the above, the Additional Analysis both (a) concludes that the Historic Preservation Alternative will mitigate impacts to cultural resources to a less- than - significant level, and (b) finds that the alternative is the environmentally superior alternative for CEQA analysis proposes. Importantly, as compared to the Hybrid Development Alternative, the Historic Preservation Alternative better meets the City's objectives — particularly the goal of adding to the City's stock of move -up housing — because it would allow for the development of 23 of the originally proposed 24 homes on the site. The foregoing illustrates the extraordinary steps the City has taken in an effort to minimize impacts to historic resources. These steps show, in compelling fashion, that the City has proactively and thoroughly encouraged the retention and reuse of historic buildings and sites, and therefore complied with both Land Use Element Goal 4 and Land Use Policy 4.2. To highlight this conclusion, we respectfully request that the language in the Final EIR that could be construed to suggest a conflict with Land Use Element Goal 4 and /or Land Use Element Policy 4.2 be revised as follows. The text of Final EIR Section 9.3 (,Page 56, first full paragraph) should be modified as follows: -5- 75A-91