75A - PH - EIR 1584 E SANTA CLARA AVE

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development of a five -acre vacant parcel with new housing will simultaneously increase the City's housing stock and provide "move up" opportunities for existing Santa Ana residents as additional, higher paying,, jobs come to the City over time. In this respect, the provision of a significant number of new homes on the project site will help the City fulfill its regionally recognized housing goals. On a more local level, the City's General Plan acts as the "constitution for all future development" within the City, and the City's Zoning Code acts to implement the General Plan on a district -by- district basis. Because the General Plan and Zoning Code are an expression of the City's land use policies, it was entirely appropriate for the City to include, as one of the project objectives, the pursuit of development that is consistent with those policies. The third objective — achieving land use compatibility — is important, but not unique. With all development proposals, the City respects the interests of neighboring landowners and communities by ensuring that proposed new development is consistent with its surroundings. In this instance, the proposed project meets that objective by providing a single family residential development with approximately 6,000 square foot lots in an area that it bounded to the east and the south by developments with similar sized residential lots. It is appropriate, but not exceptional, to expect equivalent compatibility from any alternative to the proposed project. Fourth, the City recognized that the current condition of the property must be remedied. In its current dilapidated condition, the property is a potential target of vandalism, break -ins, and unauthorized uses. To protect the public health and safety, and to improve the character of the overall community, it is important to remedy those conditions. The Old Orchard Conservancy conceded that "the Project Objectives were properly drawn" but claims that they were "misstated and misapplied in selecting alternatives for the EIR." Specifically, The Old Orchard Conservancy claimed that the EIR unlawfully constrained its evaluation of alternatives in the EIR by defining the Project Objective as the construction of exactly 24 single - family housing units, rather than the provision of some level of "move -up" housing. That statement is not accurate. While 24 single family units would achieve the "move - up" housing objective to the greatest extent possible, the EIR recognized that the Alternative Design /Cul de Sac Alternative (providing 23 houses) and the Hybrid Development Alternative (providing 21 houses) would also achieve the `Shove -up" housing objective. At a point where a significant reduction in housing was proposed — for example in the Lower Density Alternative — the EIR acknowledges that the objective of providing "move -up" housing is no longer fully achieved This determination is reasonable. While providing 1 or 3 fewer homes than the proposed project can fairly be construed as meeting the project's "move -up" housing objective, a significant reduction in the number of houses does not meet that objective. Thus, the EIR's analysis was not tied to the construction of "exactly 24 single - family housing units," and the project objectives were fairly applied to the project. This conclusion is reinforced and bolstered by the City's election to study, and the applicant's decision to pursue, a Historic Preservation Alternative that reduces the number of proposed homes from 24 to 23. Thus, the assertion that the City (or the applicant) were intransigent in their pursuit of the move - up housing objective is simply wrong. -11- 75A-97