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SEXLINGER FARMHOUSE AND ORCHARD RESIDENTIAL DEVELOPMENT PROJECT

ATTACHMENT TO THE ENVIRONMENTAL IMPACT REPORT

FEATURING THE ADDITIONAL ANALYSIS & RESPONSE TO COMMENTS ON ADDITIONAL ANALYSIS

CITY OF SANTA ANA, PLANNING AND BUILDING AGENCY 20 Civic Center Plaza, Ross Annex

P.O. Box 1988 M-20 Santa Ana, CA 92702

January 2014

Sexlinger Farmhouse and Orchard Residential Development Project Additional Analysis for Response to Comments on the Draft EIR

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ADDITIONAL ANALYSIS FOR RESPONSE TO COMMENTS ON THE DRAFT EIR

INTRODUCTION

This document provides the Additional Analysis for Response to Comments (RTC) on the Draft Environmental Impact Report (EIR) (Additional Analysis) and the Response to Comments for the Additional Analysis. The Additional Analysis features additional project information as a part of the ongoing environmental review process for the proposed Sexlinger Farmhouse and Orchard Residential Development Project. A Draft EIR for the Sexlinger Farmhouse and Orchard Residential Development Project was made available for public comment for a 45-day public review period, beginning on November 1, 2012, and ending on December 17, 2012. The previous Draft EIR is available for review from the City of Santa Ana (City). The Additional Analysis was prepared in response to public comments and simply provides additional information and analyses that merely clarifies or amplifies or makes insignificant modifications to the Draft EIR after it was circulated for public comment in December 2012. As such, recirculation was not required pursuant to Section 15088.5 subd. (b) of the CEQA Guidelines; however, the information was provided for the benefit of public review and disclosure. The Additional Analysis was available for public review from December 19, 2013 to January 17, 2014. Comments were provided by the public for the Additional Analysis. Responses to those comments have been provided in this document. SUMMARY OF ADDITIONAL ANALYSIS

During the public comment period for the Draft EIR, the City received several comment letters which requested a variation of the previously analyzed Hybrid Alternative that would preserve a portion of the existing Sexlinger Orchard in order to reduce impacts to cultural resources. In response, the City developed a variant of the Hybrid Alternative, entitled the “Historic Preservation Alternative”, and provided a document that added additional information to clarify and amplify the Draft EIR. In addition, a Carbon Sequestration Greenhouse Gas Analysis was provided as an attachment to the Additional Analysis to further amplify and clarify the greenhouse gas conclusions within the Draft EIR in response to additional public comment. The analysis was limited to clarification of information, and provided additional analysis to support the conclusions in the Draft EIR, which was previously made available for public comment. DESCRIPTION AND ANALYSIS OF HISTORIC PRESERVATION ALTERNATIVE

Description of Historic Preservation Alternative

The Historic Preservation Alternative is similar to the proposed project except that it would keep in place the existing residential structure and garage located on an approximately 10,044 square foot lot on the northwest corner of the property. The exterior of the residential structure and


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garage would be rehabilitated to Secretary of the Interior historic preservation standards, and the home and garage would be returned to single family residential use per building code requirements for habitable structures. Subsequently, the home would be available for sale for residential use. Approximately ten orange trees currently exist in this portion of the property. Additional orange trees would be planted in order to fill out the orchard, and any dead trees would be removed and be replaced with new orange trees.

Twenty-two new single family residences would be developed on the remaining areas of the property, each with a lot size ranging from 6,000 square feet to 8,611 square feet. Average lot size would be approximately 6,609 square feet, slightly larger than average lot sizes under the Preferred Alternative. The Historic Preservation Alternative would involve a roadway dedication of approximately eight feet along Santa Clara Avenue which would reduce the setback to five feet for the residential structure that is being preserved. A connection with Lyon Street to the south and Santa Clara Avenue to the north is also included in this alternative. This alternative includes a variance for a lot frontage less than the required minimum width on Lot 12. In addition, a variance for a front yard setback less than the required 20 foot setback would be required for the Sexlinger Orchard structure. No other variances are proposed.


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Figure 1. Site Plan


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Impact Analysis of Historic Preservation Alternative

The following discussion evaluates the potential environmental impacts associated with the Historic Preservation Alternative as compared to impacts of the proposed project.

Aesthetics Implementation of this alternative would permanently alter views of the site from the surrounding uses and traffic traveling along East Santa Clara Avenue. Views of the existing orange grove, which includes approximately 250 Valencia orange trees, would be replaced with views of 23 single-family residences. The existing structures located on Lot 1 would be rehabilitated in a manner that maintains the existing architectural character of the site as it is considered to be a site of local historical significance. In addition, there are approximately 10 orange trees located on Lot 1. All dead trees would be removed and additional trees would be planted to fill out the orchard. The remaining 22 single family residences would be consistent with the scale and massing of the surrounding residential neighborhoods located adjacent to the site to the north, south, and west. Mitigation measures identified in Chapter 5.1 of the Draft EIR would be applicable under this project alternative and as such, aesthetic impacts would be consistent with those identified in the discussion contained in Chapter 5.1.

Air Quality This alternative would reduce the intensity of development and result in the development of 22 new single-family residences, and rehabilitate the existing structures located on Lot 1. The PM2.5 and PM10 impacts related to construction activities would be slightly less under this alternative, compared to the proposed project. The decrease in the number of residential units would also decrease the project-related traffic and, therefore, would slightly decrease air pollutant emissions. Overall, this alternative would result in a slightly lesser impact on air quality, in comparison to the proposed project. Short term construction impacts are related to particulate matter emissions. Nevertheless, mitigation measures identified in Chapter 5.2 of the Draft EIR would be applicable under this project alternative and as such, impacts to air quality would be consistent with those identified in the discussion contained in Chapter 5.2.

Biological Resources Although this alternative would reduce the intensity and result in the development of 22 new single-family residences and rehabilitate the existing structures located on Lot 1 of the project site, the potential impacts to biological resources would be similar to the proposed project. This alternative would result in disturbance to the majority of the five acre site and result in urban developed land uses; however, trees located on Lot 1 would remain and the existing structures located on Lot 1 would be rehabilitated. All dead or decaying trees on Lot 1 would be removed and additional trees would be planted to fill out the orchard. Mitigation measures identified in Chapter 5.3 of the Draft EIR would be applicable under this project alternative and as such, impacts to biological resources would be consistent with those identified in the discussion contained in Chapter 5.3.

Cultural Resources A Cultural Resources Technical Memorandum prepared by URS in November 2013 analyzes the impacts to cultural resources under the Historic Preservation Alternative. The memo has been provided as Attachment 1 of this Additional Analysis and was used in the following analysis.


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The City Council adopted a resolution that listed the Sexlinger Farmhouse and Orchard on the Santa Ana Register of Historical Places (SARHP) on June 4, 2012. The action designated the site as “Key” as described in SAMC Section 30-2.2(2)c. Therefore, the property is considered a historical resource for purposes of CEQA.

The impacts of the Historic Preservation Alternative on the historical resource were considered using factors detailed by The National Park Service (NPS) National Register Bulletin 30: Guidelines for Evaluating and Documenting Rural Historic Landscapes (McClelland et al. 1999:15-17), which notes different 13 landscape characteristics that specifically apply to orchards as historical resources. These include: Natural Systems and Features; Spatial Organization; Land Use; Cultural Traditions; Circulation; Topography; Vegetation; Buildings and Structures; Cluster Arrangement; Small Scale Features; Constructed Water Features; Views and Vistas; and Archaeology Sites (Dolan 2009:178).

The Historic Preservation Alternative would retain the following landscape characteristics:

• Land Use; • Circulation (portions of); • Cultural Traditions; • Natural Systems and Features; • Topography; • Buildings and Structures; and • Cluster Arrangement (portions of).

Under the Historic Preservation Alternative, the extant landscape would undergo a substantial change as the vast majority of the orange trees of the project site would be removed and a six-foot block wall would be constructed immediately adjacent to the house and remnant trees. 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), and the arrangement, pattern, and shape of the orchard and trees would retain as much feeling, appearance, and character of the historical resource as feasible. 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.

The Historic Preservation Alternative prevents demolition of the residence and garage, but the immediate setting and general environment would be modified. The property would be transformed from a historic single-family residence with agricultural improvements on an approximately five acre parcel to a suburban development with a small orchard and 22 new single-family homes. The property would feature the construction of new improvements including roadways, sidewalks, and residential buildings. The vegetation that currently exists would be lost except for the small section of orange trees to be maintained adjacent to the location of the historic residence. 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.

“The historic integrity of an orchard, group of fruit trees, or a single tree is a measure of physical authenticity, conveyed by extant characteristics of features that were present during the period of


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significance…The property must have the essential physical features that enable it to convey its historic context or historical information” (Dolan 2009:178, 190). To remain historic by this definition, the orchard (and correlated improvements of the built environment) must maintain both its significance and its integrity. Under the Historic Preservation Alternative, the vast majority of orange trees would be removed; however, the property would still retain its key buildings and structures in their original location as well as several of the existing trees. Therefore, although the property would seem visually different than its historic appearance, it would still retain aspects of its location, design, setting, feeling, materials, workmanship, and association. Under the parameters set forth in Dolan’s Fruitful Legacy, the Historic Preservation Alternative would impact some of the physical features of the property; however, it would still convey character-defining features of its historic context and historical information from its period of significance and would be consistent with the Secretary of the Interior’s Standards for Rehabilitation.

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. As a rehabilitation treatment, the property would receive a compatible new use that would protect and retain the property’s character defining features, historic integrity, and major buildings and structures. The property’s location, feeling, and overall character would be maintained. Surrounding the historic residence and garage with historic and in-kind replaced trees would contribute to the property’s ability to convey a specific period, time, and an agricultural past important to the community.

Therefore, the Historic Preservation Alternative will meet the Secretary of the Interior Standards for the Treatment of Historic Properties, thereby causing impacts to the SARHP-listed resource as being mitigated to a level of less than a significant impact to the historical resource. All mitigation measures identified under Chapter 5.4 of the Draft EIR for the proposed project, except those pertaining to the demolition of the historic structure, would be applicable for this alternative. Specifically, Measures Cult-1 through Cult-6, and Paleo-1 through Paleo-4, would be required.

Geology and Soils The Historic Preservation Alternative would result in disturbance of the majority of the five-acre site preserving approximately 10,000 square feet in the northwest corner of the site and using a portion for 22 new residences and associated roadway connection of Lyon Street with East Santa Clara Avenue. Impervious surfaces would increase as noted in Chapter 5.5 of the Draft EIR. This alternative would result in similar impacts to geology and soils as compared with the proposed project. This alternative would be subjected to the same geological and seismic conditions as the proposed project which is limited to short term wind and water erosion during project construction. As such, mitigation measures identified to reduce impacts to geology and soils would be consistent with those identified in the discussion contained in Chapter 5.5.

Greenhouse Gas Emissions During construction and operation of this alternative, the majority of the GHG emissions are in the form of CO2 emissions from vehicle exhaust. As construction would be viewed as generally being less intense with fewer residences than the proposed project, GHG emissions are anticipated to be lower. Minor impacts consistent with those identified in Chapter 5.6 of the


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Draft EIR are anticipated and thus, no mitigation measures are warranted for this alternative either.

Hazards and Hazardous Materials Construction of the Historic Preservation Alternative would result in the rehabilitation of the existing structure, and rectangular outbuilding. Rehabilitation of the existing structures may result in the handling of lead based paint and asbestos containing materials, similar to the proposed project. The Phase I Environmental Site Assessment and Update Memorandum conducted for the project site also would apply to this Alternative.

Based on the construction date of the residence and outbuilding, in approximately 1913, the presence of asbestos containing materials (ACM) in roof, stucco, pipes, floor tiles may be present. In addition lead based paint may also be present based on the construction date of the residence and outbuilding. Both of these materials were banned for residential uses by the U.S. Environmental Protection Agency (EPA) in 1978. Mitigation measures included in Chapter 5.7 of the Draft EIR would be applicable to this project alternative and would reduce the impacts of hazardous materials that may be present on site.

Hydrology and Water Quality The Historic Preservation Alternative would add impervious surfaces to a majority of the site in order to accommodate the new roadway and building pads for 22 new homes. This will increase the amount of stormwater exiting the site. However, all hydrological and water quality impacts would be similar to those analyzed for the proposed project, which stated than impacts are less than significant with mitigation. As a result, this alternative would require the same mitigation as the proposed project that were listed under Chapter 5.8 of the Draft EIR, which includes the requirements of the Santa Ana Regional Water Quality Control Board and implementation structural and non-structural BMPs to reduce stormwater runoff and to limit urban pollutants to the greatest extent possible.

Land Use and Planning Implementation of the Historic Preservation Alternative would result in the construction of 22 new homes and would preserve the existing structure and outbuilding in its present location. This alternative would result in one parcel (2 new homes) less than the proposed project. This alternative would be consistent with the existing zoning and land use designation of Single Family Residential (R-1) and Low Density Residential (LR-7); however, variances would be required for two of the parcels. Parcel No. 12 would require a variance to allow for the reduction of street frontage as a result of the proposed parcel layout along the curved portion of Lyon Street. Another variance would be required for the front yard setback of the existing Sexlinger Orchard structure since roadway dedication requirements along Santa Clara Avenue would reduce the building’s front yard setback to five feet, which would not meet zoning requirements. The land use, scale and density of the homes built in this alternative would be consistent with the zoning and would be compatible the residential developments located within the vicinity of the project. This alternative would also rehabilitate the structure to the Secretary of the Interior historic preservation standards, and the home would be returned to single family residential use pursuant to building code requirements for habitable structures. Other uses for the Sexlinger Orchard structures, other than those stated within the existing zoning and land use designations, would require a zone change and land use designation change, and are not considered under this


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alternative. In addition, exterior physical modifications to the Sexlinger Orchard property, other than those that can be approved administratively, would be subject to a certificate of appropriateness from the Historic Resources Commission. No mitigation is required.

Noise Construction noise impacts would be similar to the proposed project, which is considered to be less than significant. The typical long-term noise impacts from residential developments are from the vehicular traffic going into and out of the residential community. Noise impacts from vehicle trips under the Historic Preservation Alternative are be expected to be marginally less than noise levels of the proposed project since the development of one fewer parcel would slightly decrease the project related traffic, and would therefore decrease traffic related noise. Analysis of the proposed project under Chapter 5.10 of the Draft EIR had concluded that there would be no environmental impacts. No mitigation is required.

Population and Housing This alternative would result in one fewer parcel relative to the proposed project, which would result in a minor decrease in population growth than originally proposed. The analysis for the proposed project under Chapter 5.11 of the Draft EIR, which had determined that there would be no significant impacts, would be applicable to this alternative. This alternative would not displace people since the existing site is vacant and given the limited size of the subdivision, the alternative would not induce substantial population growth in the area. No mitigation is required.

Public Services The Historic Preservation Alternative would result in the construction of 22 new homes and the rehabilitation of the Sexlinger Orchard structures. The analysis of the proposed project provided under Chapter 5.12 of the Draft EIR, which had concluded that no significant impacts would occur in regard to public services and facilities, would be applicable for this alternative since it would result in fewer new homes. No mitigation is required.

Recreation This alternative would result in an increased demand for recreation services and facilities, specifically on Portola Park, which is located adjacent to the project site. However, the increase in demand from 22 new residential homes and the rehabilitated Sexlinger Orchard structure as a residence would be similar to the proposed project analyzed in Chapter 5.13 of the Draft EIR, and is not expected to result in significant impacts or lead to substantial physical deterioration of park facilities. No mitigation is required.

Transportation and Traffic With the reduction of residential dwelling units to 23 residences, project impacts at build-out would still occur at the intersection of Santa Clara Avenue and Wright Street. This impact was based on the assumption of the current unsignalized operation of the intersection with Santa Clara Avenue as free-flowing and Wright Street as the minor street controlled by a stop sign. The one lane in each direction configuration restricts traffic flow resulting in a level of service F condition, thus requiring some form of mitigation. The Santa Clara Avenue and Wright Street intersection are listed in the existing City of Santa Ana Traffic Signal Priority List. As such, a traffic signal is warranted in the future at this location and the developer will be required to


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contribute its fair share fee towards the construction of a traffic signal. Mitigation measures identified in Chapter 5.14 of the Draft EIR would be applicable to this alternative and would alleviate circulatory issues exacerbated by the project.

Utilities This alternative would result in similar impacts for utilities as the proposed project. Utilities to service the 22 residences and the Sexlinger Orchard structures would be required and would require connections similar to the proposed project for existing utilities (i.e., water, sewer, etc.). Similar to impacts analyzed for the proposed project under Chapter 5.15 of the Draft EIR, this alternative would not result in excess demand for utilities or result in a need for new water nor wastewater treatment facilities similar to the proposed project. No mitigation is required.

Ability to Meet Project Objectives

The Historic Preservation Alternative would result in reuse of a portion of the Sexlinger Orchard property in order to accommodate residential development on the project site. However, this alternative would also result in rehabilitation of the existing Sexlinger Orchard structures, in place, to the Secretary of Interior Standards. The result is less than significant impacts to cultural and other resources. This alternative would also provide needed housing that is similar to the surrounding uses in character and cohesion within City of Santa Ana while providing land uses that are consistent with the existing General Plan Land Use designation and Zoning designation of LR-7 and R-1. This alternative would be able to realize the project objectives, as discussed in Section 3.4 of the Draft EIR. In addition, this alternative would be the environmentally superior alternative over the originally proposed project. CARBON SEQUESTRATION GREENHOUSE GAS ANALYSIS

A Carbon Sequestration Greenhouse Gas Technical Memorandum was prepared by URS in June 2013 to address comments received by Guy Stivers (letter dated May 10, 2013). The Technical Memorandum is included in Attachment 2. The following is brief summary of the analysis. Summary of Carbon Sequestration Greenhouse Gas Analysis

An analysis of the carbon sequestration to the project’s GHG emissions from the loss of the orange tree orchard was modeled with CalEEMod. CalEEMod calculates the net change in carbon sequestration based on the existing land use and proposed vegetative cover. This net change in carbon sequestration is a one-time change that will occur when the orchard is converted to residential homes.

Table 1 summarizes the proposed project’s direct and indirect GHG emissions and takes into account carbon sequestration to the project’s GHG emissions from the loss of the orchard.


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Table 1. Direct and Indirect GHG Emissions

GHG Emissions Source CO2 CH4 N2O CO2e 1

Direct - Area Source - Summer (Table 4) (lbs/day) 500 - - 500

Direct - Mobile Source - Summer (Table 4) (lbs/day) 2,228 - - 2,228

Direct - Area Source - Winter (Table 4) (lbs/day) 753 - - 753

Direct - Mobile Source - Winter (Table 4) (lbs/day) 2,020 - - 2,020

TOTAL DIRECT GHG Emissions (MT/year) 2 455

Electricity Emission Rate (lbs/MWh) 3 681 0.0283 0.00623 -

Global Warming Potential (GWP) 4 1 21 310 -

Indirect – Electricity Usage (24 Households) (MWh/year) 5 168

Indirect – Electricity Usage (lbs/year) 114,409 4.75 1.05 114,833

TOTAL INDIRECT GHG Emissions (MT/year) 6 52

TOTAL DIRECT + INDIRECT GHG Emissions 507

CARBON SEQUESTRATION (MT/year)2 1,300

TOTAL + SEQUESTRATION 1,807 Note: 1 CO2 equivalent (CO2e) is a measure for comparing carbon dioxide with other GHGs, which generally have a higher Global

Warming Potential (GWP) based on the amount of those other gases multiplied by the appropriate GWP factor, commonly expressed as metric tons of carbon dioxide equivalents (MTCO2e).

2 The total direct emissions were calculated by adding up the area source and mobile source emissions for winter and summer together and dividing by 2 to get the average daily emissions, which were then multiplied by 365 days and converted to metric tons (MT).

3 Emission factors were obtained from the California Climate Action Registry’s (CCAR) “General Reporting Protocol” Table C-2. 4 GWP factors were obtained from the California Climate Action Registry’s (CCAR) “General Reporting Protocol” Appendix A. 5 According to the California Air Pollution Control Officers Association’s (CAPCOA) “CEQA & Climate Change” guidance

document, the average rate of electrical consumption for residential uses is 7,000 kilowatt hours (kWh) per year per household.

6 Total pounds per year were converted to metric tons using the conversion factor, 1 MT = 1,000 kg Source: Analysis of Air Quality/Global Climate Change Impacts Technical Memorandum, March 2011. URS Corporation. Carbon Sequestration Greenhouse Gas Analysis Technical Memorandum, June 2013. URS Corporation.

As indicated in the Table 1, the proposed project’s maximum annual emissions are 507 metric tons of carbon dioxide equivalents (MTCO2e) from project operations. It is conservatively estimated that 1,300 metric tons could be sequestered by the existing orchard. So, with the loss of the existing orchard, 1,300 metric tons of sequestration would need to be added to the project’s direct and indirect GHG emissions, resulting in total 1,807 metric tons as shown in Table 1. This accounts for 0.0001 percent of California’s GHG emissions, and is less than SCAQMD’s significance threshold of 3,000 metric tons. Therefore, the GHG emissions from project construction and operations are considered less than significant.

Sexlinger Farmhouse and Orchard Residential Development Project Response to Comments For Additional Analysis


COMMENTS AND RESPONSES FOR THE ADDITIONAL ANALYSIS FOR RESPONSE TO COMMENTS ON THE DRAFT EIR

CEQA REQUIREMENTS

In accordance with Section 15088, 15089, and 15132 of the California Environmental Quality Act (CEQA), the City of Santa Ana (City) has prepared the Environmental Impact Report (EIR) for the Sexlinger Farmhouse and Orchard Residential Development Project. This Comments and Response section, combined with the Additional Analysis for Response to Comments on the Draft EIR, will serve as an attachment to the original Response to Comments and the Draft EIR that make up the Final EIR. Any additional City recommendations or requirements during the certification process will make up the final components of this EIR. PUBLIC REVIEW PROCESS – ADDITIONAL ANALYSIS FOR RESPONSE TO

COMMENTS ON DRAFT EIR

The Additional Analysis for Response to Comments (RTC) on the Draft EIR (Additional Analysis) featured additional project information as a part of the ongoing environmental review process for the proposed Sexlinger Farmhouse and Orchard Residential Development Project. The analysis and new project alternative were prepared in response to public comments and provide additional information and analyses that merely clarifies or amplifies or makes insignificant modifications to the Draft EIR after it was circulated for public comment in December 2012. The new alternative kept the farmhouse at its current location, and the effects were found not to be significant as they resulted in lesser impacts. As such, recirculation was not required pursuant to Section 15088.5 subd. (b) of the CEQA Guidelines; however, the information was provided for the benefit of public review and disclosure. The Additional Analysis was made available for public review and comment from December 19, 2013 to January 17, 2014. The City of Santa Ana requested that reviewers limit their comments to the information provided in the Additional Analyses document only. COMMENTS AND RESPONSES

During the public review period of the Additional Analysis from December 19, 2013 to January 17, 2014, several organizations and private parties submitted comments to the City. Some comments were also received prior to the Additional Analysis review period, but after the public review period of the Draft EIR. Each of these correspondences from the organizations and private parties are included this response to comments document on the Additional Analysis. Below is a list of the written comments that were received. A response is provided for each comment.

Deborah M. Rosenthal, Sheppard, Mullin, Richter & Hampton LLP (August 21, 2013) Jeannie Gillett, The Old Orchard Conservancy (November 6, 2013) Jeannie Gillett, The Old Orchard Conservancy (January 17, 2014) Deborah M. Rosenthal, Sheppard, Mullin, Richter & Hampton LLP (January 17, 2014)



Diana Hardy (January 20, 2014) Alan Lawson, Santa Ana Historical Preservation Society (January 24, 2014)



Commenter: Deborah M. Rosenthal, Sheppard, Mullin, Richter & Hampton LLP Address Costa Mesa, CA Comment Date: August 17, 2013 Response to Comment # 1 Thank you for your comment. The commenter indicates that additional alternatives are needed, and recommends a project alternative that would preserve the existing Sexlinger structure in place. As stated in CEQA Guidelines Section 15126.6, “an EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project.” [CEQA Guidelines §15126.6(a)]. “The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen on or more of the significant effects.” [CEQA Guidelines §15126.6(c)]. The analysis in the Draft EIR included 7 different alternatives. A variant of the Hybrid Development Alternative, entitled the Historic Preservation Alternative, was analyzed after this comment was received. The Historic Preservation Alternative, which was analyzed in the Additional Analysis, provides for a total of 23 residences, which includes 22 new single family residences and the rehabilitation of the Sexlinger Farmhouse and Orchard in situ. The exterior of the residential structure and garage would be rehabilitated to Secretary of the Interior historic preservation standards, and the home and garage would be returned to single family residential use per building code requirements for habitable structures. Subsequently, the home would be available for sale for residential use. Approximately ten orange trees currently exist in this portion of the property. Additional orange trees would be planted in order to fill out the orchard, and any dead trees would be removed and be replaced with new orange trees. The analysis concluded that, with the mitigation measures provided, impacts to cultural resources would be less than significant. The commenter also references concerns presented from the Planning Commission during the Project’s February 11, 2013, Planning Commission meeting. The concern referenced in the comment was presented by Commissioner Chair Alderete, which stated concerns regarding the compatibility of two story houses adjacent to single family houses. As stated in the Draft EIR and the Additional Analysis, the project site is currently zoned Single Family Residential (R-1), and has a General Plan Land Use designation of Low Density Residential (LR-7). Two story residential developments, up to 27 feet tall, are permitted under this zoning and General Plan designation, and the proposed Project features development that consistent with these applicable regulations. Further, two story homes are located approximately 500 feet from the proposed Project along the northwest corner of North Wright Street and Santa Clara Avenue, as well as North Linwood Street. Santa Clara Street currently features a mixture of single and two story homes. As such, the project would be compatible in density and character with the existing residential land uses surrounding the Project site. Compatibility impacts would be mitigated with applicable design standards pursuant to the requirements set forth by the City of Santa Ana.



Response to Comment # 2 The comment references a recent court of appeal case ruling for Masonite Corporation v. County of Mendocino, which was in response to Granite Construction Company’s (Granite) terrace mining/sand and gravel quarry project adjacent to the Russian River near Ukiah. The ruling determined that Agricultural Conservation Easements (ACEs) constitute legally-feasible mitigation for the direct loss of Prime Farmland, noting “ACEs may appropriately mitigate for the direct loss of farmland when a project converts agricultural land to a nonagricultural use, even though an ACE does not replace the onsite resources.” The commenter notes that this court case is relevant to the Sexlinger Farmhouse and Orchard Project, and mitigation efforts to preserve agricultural lands on or off-site is applicable. However, the court ruling was to provide mitigation for the loss of farmlands classified as “Prime Farmland” under the Department of Conservation’s (DOC) Farmland Mapping and Monitoring Program (FMMP). As addressed in the Draft EIR, the proposed project site, while historically used as an orange orchard, is not classified as “Prime Farmland” under the (FMMP). Instead, all digitally available FMMP maps (2006, 2008, and 2010) from the DOC classifies the project site as “Urban and Built Up Land.” Further, the Project site is not located in an agricultural preserve or has been designated as farmland of local importance. The Project site has not been irrigated for over five years because it has been unoccupied and out of production since 2006. As stated in the Draft EIR, more than half of the trees that were historically associated with the Orchard have been removed between 1980 and 2006. Further, the existing orchard is located on a relatively small parcel that is located within an urban context. As such, the site is not considered Prime Farmland and there would be no impacts. Therefore, mitigation efforts to preserve agricultural lands would not be applicable.



Commenter: Jeannie Gillett, The Old Orchard Conservancy Address Santa Ana, CA Comment Date: November 6, 2013 Response to Comment # 1 Thank you for your comment. The commenter indicates that additional alternatives should be evaluated, and recommends a project alternative that would preserve the existing Sexlinger structure in place. Please see Response to Comment #1 provided for the letter written by Deborah M. Rosenthal, dated August 21, 2013. The response outlines that seven project alternatives were provided in the Draft EIR, and that a variant of an alternative, entitled the Historic Preservation Alternative, was analyzed in the Additional Analysis. The Historic Preservation Alternative preserves the Sexlinger structures in situ, and would result in less than significant impacts to cultural resources. Response to Comment # 2 The comment references a recent court of appeal case ruling for Masonite Corporation v. County of Mendocino. Please see Response to Comment #2 provided for the letter written by Deborah M. Rosenthal, dated August 21, 2013. The response outlines that the Sexlinger Orchard is not designated as “Prime Farmland,” and that mitigation measures identified in the court case are not applicable to this Project.



Commenter: Jeannie Gillett, The Old Orchard Conservancy Address Santa Ana, CA Comment Date: January 17, 2014 Response to Comment # 1 Thank you for the comment. The commenter discusses the designation of the property by the Santa Ana City Council to the Santa Ana Register of Historical Places (SARHP) as a “Key” resource under SARHP Condition 6. In addition, the commenter notes that the use of the Secretary of Interior Standards for the Treatment of Historic Properties, and other guidance documents developed by the National Park Service and federal government, were inadequate for assessing significant impacts to the historical resource under the Historic Preservation Alternative. This comment also disagrees with a portion of the Historic Preservation analysis, noting that the property will no longer be used as it was historically. As noted in the Historic Preservation Alternative, the designation of the property to the SARHP as a “Key” resource, established the property as a historical resource for purposes of CEQA, under CEQA Guidelines section 15064.5. In addition, CEQA Guidelines state that, generally, a project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties and Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings shall be considered as mitigated to a level of less than a significant impact on the historical resource. As part of the analysis using the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings, and to identify and assess the character-defining features of the property type and its associated major aspects of historic integrity, guidance documents developed by the National Park Service and Department of Interior were used, including Fruitful Legacy: a Historic Context of Orchards in the United States, with Technical Information for Registering Orchards in the National Register of Historic Places and National Register Bulletin 30: Guidelines for Evaluating and Documenting Rural Historic Landscape. Therefore, to consider if a substantial adverse change and significant impacts may occur to the historical resource, it was appropriate and adequate to apply these standards and guidelines to assess if the Historic Preservation Alternative will cause a substantial adverse change to the historical resource, as a whole. These major standards and guidelines are discussed on the following page, and are summarized from the analysis included in the Historic Preservation Alternative. Overall, the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings, and the appropriate guidance documents for the property type, are considered by the federal government and historic preservation professionals across the United States as “best management practices” for actions affecting significant historic districts, buildings, sites, structures, and objects. These publications describe a series of concepts that owners or managers of historical properties are encouraged to incorporate into projects involving historical resources, and focus specifically on maintaining, repairing and replacing historic



materials, as well as designing new additions or making alterations. The Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings pertain to historical resources exhibiting a variety of construction materials, sizes and use, and encompass both the exterior and interior of properties. They also encompass related landscape, site, and environmental features, as well as attached, adjacent, or related new construction. The Standards for Rehabilitation are intended to be used when alterations and additions will be made to a property to ensure they are compatible with the property’s historic character, use, form, and integrity, and recognize that changes to historical resource may occur over the course of its existence and use. The Historic Preservation Alternative analyzed the potential impacts to the historical resource using the above guidance and publications, and determined that the Historic Preservation Alternative would meet the Secretary of the Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings. While the project will cause changes to the property as a whole, the property will 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. The spatial relationship between the residence and garage, orientation of the property, and the property’s visual narrative of a small-scale orchard will be retained. Surrounding the historic residence and garage with historic and in-kind replaced trees will contribute to the property’s ability to convey a specific period, time, and an agricultural past important to the community. The new trees will match the existing type (Valencia, grafted to lemon rootstock), arrangement, pattern, and shape of the orchard and trees to retain as much feeling, appearance, and character of the historical resource as feasible. These changes are consistent with the Secretary of Interior Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings which recommends for sites and setting:

• Preserving buildings and their features as well as features of the site, and landscape features, that are important in defining its overall historic character.

• Retaining the historic relationship between buildings and the landscape features of the setting.

• Preserving important landscape features, including ongoing maintenance of historic plant material.

• Replacing materials in-kind.

In addition, as noted by the commenter, while the Historic Preservation Alternative would not allow the property to be used as it was historically as a whole; the retention of the residence, garage, and the character of the orchard will allow the property to retain and exhibit a portion of its historic use, as well as receive a compatible new use that requires minimal change to its distinctive materials, features, spaces, and spatial relationships; therefore, meeting the Secretary of Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings.

In conclusion, the Secretary of Interior’s Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings allow changes to be implemented to a property, provided they do not diminish the overall integrity of the property by retaining character-defining features, and are compatible with the property’s appearance, form, context, and visual narrative.



Response to Comment # 2 The commenter discusses particular site and landscape elements and characteristics they feel may be impaired by the implementation of the Historic Preservation Alternative. This includes impairments to the property’s circulation network, natural systems, setting and relationship with the landscape, and spatial organization, and as a result, impacts should not be considered mitigated to a level less than significant. The Historic Preservation Alternative noted that some or portions of those elements may be impaired. However, the analysis also notes the property will retain numerous landscape characteristics that convey its significance and integrity, as detailed in National Register Bulletin 30: Guidelines for Evaluating and Documenting Rural Historic Landscapes:

• Land Use • Circulation (portions of); • Cultural Traditions • Natural Systems and Features; • Topography; • Buildings and Structures; • Cluster Arrangement (portions of)

The property would retain its land use as a small-scale orchard and residence, though the property will be much smaller. The cultural tradition of growing Valencia orange trees grafted to lemon rootstock will be retained; however, fewer trees will be in the orchard. Some of the circulation network located between the existing trees will be retained; however, a large portion of the network will be lost by new the development of the rest of the property. While the Natural Systems and Features of the land itself would not be lost, nor would the Topography, under the Historic Preservation Alternative, neither would likely be recognizable as what exists currently. The buildings and structures –specifically, the residence and garage- will remain on-site preserving their cluster arrangement; however, their overall setting and relationship with the landscape will be impaired by the construction of additional residences. However, these elements have already been impacted over time, through the extensive residential and commercial development that presently surrounds the property. Therefore, though the property would seem visually different than its historic appearance, it will still retain its historic integrity aspects of its location, design, setting, feeling, materials, workmanship, and association. Under the Historic Preservation Alternative, the property would retain its major built environment and landscape character-defining features, historic context, and historical information from its period of significance. As a result, a substantial adverse change would not occur to the property and the alternative would have a less than significant impact to historical resources. Response to Comment # 3 The commenter indicates that additional alternatives are needed, and recommends a project alternative that would preserve the existing Sexlinger structure in place, and references a letter



from the Old Orchard Conservancy, dated November 6, 2013. Please see Response to Comment #1 provided for the letter written by Deborah M. Rosenthal, dated August 21, 2013. The response outlines that seven project alternatives were provided in the Draft EIR, and that a variant of an alternative, entitled the Historic Preservation Alternative, was analyzed in the Additional Analysis. The Historic Preservation Alternative preserves the Sexlinger structures in situ, and would result in less than significant impacts to cultural resources. Response to Comment # 4 The comment references a recent court of appeal case ruling for Masonite Corporation v. County of Mendocino. Please see Response to Comment #2 provided for the letter written by Deborah M. Rosenthal, dated August 21, 2013. The response outlines that the Sexlinger Orchard is not designated as “Prime Farmland,” and that mitigation measures identified in the court case are not applicable to this Project.



Commenter: Deborah M. Rosenthal, Sheppard, Mullin, Richter & Hampton LLP Address Costa Mesa, CA Comment Date: January 17, 2014 Response to Comment # 1 Thank you for your comment. The comment indicates that the removal of several trees from the orchard would affect the property’s significance and integrity. Please see Response to Comments #1 and #2 provided for the letter written by Jeannie Gillett, dated January 17, 2014. The comments provide details on the how the Project is consistent with the Secretary of Interior Standards for Rehabilitation, and that the property will still retain its historic integrity aspects of its location, design, setting, feeling, materials, workmanship, and association. Response to Comment # 2 The comment references a recent court of appeal case ruling for Masonite Corporation v. County of Mendocino. Please see Response to Comment #2 provided for the letter written by Deborah M. Rosenthal, dated August 21, 2013. The response outlines that the Sexlinger Orchard is not designated as “Prime Farmland,” and that mitigation measures identified in the court case are not applicable to this Project. Response to Comment # 3 The commenter references concerns presented from the Planning Commission during the Project’s February 11, 2013, Planning Commission meeting. The concern referenced in the comment was presented by Commissioner Chair Alderete, which stated concerns regarding the compatibility of two story houses adjacent to single family houses, and concerns regarding shade and shadow cast upon adjacent properties. As stated in the Draft EIR and the Additional Analysis, the project site is currently zoned Single Family Residential (R-1), and has a General Plan Land Use designation of Low Density Residential (LR-7). Two story residential developments, up to 27 feet tall, are permitted under this zoning and General Plan designation, and the proposed Project features development that consistent with these applicable regulations. Further, two story homes are located approximately 500 feet from the proposed Project along the northwest corner of North Wright Street and Santa Clara Avenue, as well as North Linwood Street. Santa Clara Street currently features a mixture of single and two story homes. As such, the project would be compatible in density and character with the existing residential land uses surrounding the project site. Compatibility impacts would be mitigated with applicable design standards pursuant to the requirements set forth by the City of Santa Ana. Further, shade and shadow analysis are not conducted for two story residential developments since they do not cast a large enough shadow to have been determined as a significant impact pursuant to the California Environmental Quality Act. The front and rear yard setbacks required by the R-1 zoning, as well as the northern orientation of the project development, would prevent any substantial shade or shadow impacts.



Commenter: Diana Hardy Address Santa Ana, CA Comment Date: January 20, 2014 Response to Comment # 1 Thank you for your comment. This comment discusses the designation of the property to the SARHP as a “Key” Resource. Please see Response to Comments #1 provided for the letter written by Jeannie Gillett, dated January 17, 2014. The comment provides details on the Sexlinger designation, and how the Project is consistent with the Secretary of Interior Standards for Rehabilitation. Response to Comment # 2 Thank you for your comment. The commenter indicates that the preservation of the Sexlinger structure as a residence limits other uses, and indicates a preference for a project alternative that would allow the site to function as an educational entity. As stated in CEQA Guidelines Section 15126.6, “an EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project.” Furthermore, an EIR is “not required to consider alternatives which are infeasible.” [CEQA Guidelines §15126.6(a)]. “The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen on or more of the significant effects.” [CEQA Guidelines §15126.6(c)]. The proposed project, as filed and presented to the City of Santa Ana Planning and Building Agency, is for development of the site with 24 single family residences. As such, any alternatives to the proposed project would require some aspect for the development of single family residences. The Historic Preservation Alternative analyzed in the Additional Analysis provides for a total of 23 residences, which includes 22 new single family residences and the rehabilitation of the Sexlinger Farmhouse as a residence. The alternatives analysis would not include other potential land uses of the site such as museums, urban gardens, or education facilities because those land uses are not a part of the proposed project, and were not part of the historical development of the site. The original use of the property was as a single family residence. The proposed project is not to determine the land use of the site and the alternatives analysis is not to identify other land uses for the site itself, but rather, to find alternatives to the proposed project, which was the development of single family residences. Therefore, the Historic Preservation Alternative is consistent with the CEQA Guidelines. It should be noted that an Urban Garden Alternative was analyzed in the Draft EIR; however, this alternative could not reduce impacts to historical resources to a less than significant level. Further, as discussed in the Draft EIR, the site is zoned Single Family Residential (R-1) zoning



with a General Plan designation of Low Density Residential (LR-7). The construction of an Urban Garden Alternative and other type of educational uses would conflict with the Single Family Residential (R-1) zoning and Low Density Residential (LR-7) designation. In addition, the other uses as suggested by the commenter would have the potential of introducing new features into the site which, in some cases, would be greater than those discussed in the alternatives included in the Draft EIR. As stated in the EIR, any modifications, changes, improvements, or structural changes to the existing residential structure, and outbuilding would potentially result in significant and unavoidable impacts to the historic resource. The potential development of the site, including parking areas and outdoor lighting and additional traffic, could diminish the significance of historic associations and lead to losses of historic features, setting, spaces, and relationships. Further, educational uses to the site would not be part of the original use of the site as an orange grove and family residence, and would result in significant impacts to the historic resource that cannot be mitigated to less than significance. Response to Comment # 3 Impacts to Open Space were analyzed and presented in the Draft EIR as well as the Additional Analysis. The Project site features a General Plan Land Use designation of Low Density Residential (LR-7) and the zoning designation of Single Family Residential (R-1). In addition, the property has been privately owned and has not been open to the public as public open space or a public green area, and is not considered or intended as open space by the City. The analysis provided for the Historic Preservation Alternative concluded that the addition of 23 single family residences would not significantly impact recreational facilities to the City. Response to Comment # 4 Section 5.14 (Transportation and Traffic) of the Draft EIR had discussed potential traffic impacts, and the Additional Analysis provided additional information regarding traffic impacts associated with the Historic Preservation Alternative. In the Draft EIR, it was determined that for the “With” project and “Without” project conditions of the proposed project, there is expected to be a significant impact to one of the study intersections as a result of the project. The intersection of Santa Clara Ave/Wright Street is expected to be impacted in the PM peak hour for the buildout condition as a result of the proposed project. Mitigation Measure TRF-2 reduced this impact to a less than significant level. The Historic Preservation Alternative, which features one fewer residence, would have similar impacts. Therefore, the mitigation measure in the proposed project would be applicable for the Historic Preservation Alternative. The measure is as follows: TRF-2: Implementation of a traffic signal is recommended at the intersection of Santa Clara Avenue and Wright Street. The project will be subject to fair-share improvements, and the project applicant will be required to finance the improvements required on a pro-rata fair-share basis.



Commenter: Alan Lawson, Santa Ana Historical Preservation Society Address Santa Ana, CA Comment Date: January 24, 2014 Response to Comment # 1 Thank you for the comment. The commenter requests information relating to the number of trees that would be located in the remaining portions of the orchard, the spatial relationship of the trees to the farmhouse building, and whether guarantees for future preservation of the building and remnant orchard. As noted in the Historic Preservation Alternative, approximately ten orange trees will be retained. It is expected that an additional 6 orange trees would be planted in order to fill out the orchard and any dead trees would be removed and be replaced with new orange trees. As a result, the orchard would have approximately 16 trees. The replacement and addition of the trees would be conducted in-kind, matching the existing type (Valencia, grafted to lemon rootstock), arrangement, pattern, and shape of the orchard and trees to retain as much feeling, appearance, and character of the historical resource as feasible. Therefore, the new trees planted in-kind to the existing ones would retain their spatial relationship to the historic buildings and structures to retain its historical context. Response to Comment # 2 The commenter requests if there is any protection for the remaining parcel to ensure that future owners maintain the historical integrity of the site. As stated in the Additional Analysis, the property is designated as a “Key” resource in the City of Santa Ana. Pursuant to Section 30-6, any exterior physical modifications to the Sexlinger Orchard property, other than those that can be approved administratively, as well as relocation, or demolition, would be subject to a certificate of appropriateness from the Historic Resources Commission. The applicant would be required to complete and submit an application for Historic Resources Commission review to the Planning Division, and the Planning Division would schedule the required Historic Resources Commission public hearing. At the public hearing, the Historic Resources Commission will evaluate the merits of the proposal, consider public input, and provide appropriate comments for the project prior to taking action on the proposal. The Historic Resources Commission would then issue the certificate of appropriateness upon finding that the proposed modification(s) does not substantially change the character and integrity of the historic property. This process provides protection for the Sexlinger Farmhouse and Orchard to ensure that future owners do not adversely impact the integrity of the resource.

Attachments: Technical Memoranda

1. Historic Preservation Alternative Cultural Resources Technical Memorandum

2. Carbon Sequestration Greenhouse Gas Analysis for the Sexlinger

Farmhouse and Orchard Residential Development Project Technical Memorandum

Technical Memorandum

Date: November 22, 2013 To: City of Santa Ana, Planning and Building Agency

From: Jeremy Hollins, URS Corporation

Subject: Sexlinger Orchard Project – Historic Preservation Alternative Cultural Resources Technical Memorandum

Attachments: Project Area Maps

Project Plans Site Photos City Council of the City of Santa Ana Minutes, June 4, 2012

This technical memorandum was prepared by URS Corporation (URS) at the request of the City of Santa Ana (City), to evaluate impacts to the Sexlinger Orchard at 1584 East Santa Clara Avenue, Santa Ana, California, from the Sexlinger Orchard Project Historic Preservation Alternative. The Historic Preservation Alternative is an additional alternative being considered and analyzed for the Revised Draft Environmental Impact Report (DEIR), as part of the Sexlinger Orchard Project (project).

The City Council adopted a resolution that listed the Sexlinger Farmhouse and Orchard on the Santa Ana Register of Historical Places (SARHP) on June 4, 2012. The action designated the site as “Key” because it met the SARHP Condition 6 for its status as a building or structure that was associated with the citrus orchard business, which was once common but is now rare due to the conversion of most of the City’s historic orange orchards to residential and commercial use by the mid- to late twentieth century (Attachment – City Council of the City of Santa Ana Minutes; City of Santa Ana 2012a and 2012b). The SARHP-listed property is therefore considered a historical resource for purposes of the California Environmental Quality Act (CEQA).

Based on the available information, URS has concluded that the Historic Preservation Alternative will meet the Secretary of the Interior's Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings. Therefore, per CEQA Guidelines Section 15064.5(b)(3), by meeting the Secretary of the Interior's Standards for the Treatment of Historic Properties, impacts from the project would be considered as mitigated to a level of less than a significant impact to the SARHP-listed resource, which is considered a historical resource for purposes of CEQA.

Background

In 2007, a Memorandum for the Record was prepared by Sapphos Environmental Inc. (Heumann and Howell-Ardila 2007) for the project. The memo assessed the eligibility of the residence and orange grove in the project, based on a site inspection and historic research. The

memo concluded that the property appeared to be eligible for listing in the California Register of Historical Resources (CRHR) and the SARHP as one of the last remaining examples of Santa Ana’s history as an important orange-growing region (CRHR under Criterion 1 - “associated with events that have made a significant contribution to the broad patterns of local or regional history or the cultural heritage of California or the United States” and the SARHP under Criterion 6 - “buildings or structures that were connected with a business or use that was once common but is now rare”). The CEQA Initial Study (May 2011) that was prepared for the proposed project incorporated these findings. However, in 2008, Discovery Works, Inc. and Foothill Resources, Ltd. prepared the Cultural Study Report, Empire Homes Project, (Tentative Tract Map 17231), 1584 E. Santa Clara Avenue, Santa Ana, Orange County, California (Padon and Marvin 2008). Padon and Marvin evaluated the property as not eligible for listing in the CRHR or SARHP, concluding that while the property was associated with the development of the citrus industry in the early decades of the twentieth century, small citrus operations did not play a significant role in the development of Santa Ana, either physically or culturally.

In July 2011, the City circulated for public comment the DEIR for the proposed Sexlinger Orchard Project (then the TAVA Development Company Project) (Applicant). The DEIR concluded that the historic-age residence and associated orchard in the project was not eligible for listing in the CRHR or SARHP, and consequently as a historical resource for purposes of CEQA. The DEIR was available for public comments from July 27 to October 10, 2011. During the public comment period, the City received comments from the public requesting that the historic-age residence and orange grove within the project be re-evaluated as eligible for listing in the CRHR and SARHP, and consequently as a historical resource for purposes of CEQA. An extension to the public comment period was made to allow additional time to review the Cultural Resources technical appendix. Subsequently, the City concluded that a technical memorandum should be completed to re-evaluate the property for eligibility for listing in the CRHR and the SARHP, and to re-analyze the project’s impacts, for purposes of CEQA should the property be determined a historical resource for purposes of CEQA.

In March 2012, URS completed a supplementary technical memorandum reporting the results of the following: a review of previous studies and evaluations of the property at 1584 East Santa Clara Avenue, Santa Ana, California; additional historic research; and a re-evaluation of the property for eligibility for listing in the CRHR, the SARHP, and as a historical resource for purposes of CEQA. URS concluded that the property did not appear to be eligible under any of the CRHR criteria and therefore was not recommended as eligible for listing under the CRHR. However, the property appeared to be eligible for listing in the SARHP under Condition 6 for its status as a building or structure that was associated with the citrus orchard business, which was once common but is now rare, due to the conversion of most of the City’s historic orange orchards to residential and commercial use by the mid- to late twentieth century. In March 2012, the City of Santa Ana recirculated the DEIR with the revised eligibility recommendations for the Sexlinger Orchard.

On April 5, 2012, the Santa Ana Historical Resources Commission (Commission) considered placing the Sexlinger Orchard on the SARHP but denied the listing; however, on appeal, the Santa Ana City Council voted on June 4, 2012 to overturn the Commission’s decision and list the Sexlinger Orchard in the SARHP, overriding the Commission’s decision (City of Santa Ana 2012a and b; Attachment – City Council of the City of Santa Ana Minutes;). The City Council

action designated the site as “Key” because it met the SARHP Condition 6 for its status as a building or structure that was associated with the citrus orchard business, which was once common but is now rare due to the conversion of most of the City’s historic orange orchards to residential and commercial use by the mid- to late twentieth century (City of Santa Ana 2012). Therefore, as a locally-listed property, the Sexlinger Orchard is considered a historical resource under the SARHP for purposes of CEQA.

As a result of the City Council’s decision to list the property and public testimony, the Historic Preservation Alternative was proposed as an alternative for the retention of portions of the historical resource. The Historic Preservation Alternative is similar to the Preferred Alternative except that it would keep in place the existing Craftsman-style residence and garage located on an approximately 10,044 square foot lot on the northwest corner of the property. Changes to the overall property, including the landscape, exterior of the Craftsman-style residential building and garage, and the orchard would meet the Secretary of the Interior Standards for Rehabilitation, and these buildings will be returned to single family residential use per building code requirements for habitable structures. Subsequently, the home will be available for sale for residential use. Approximately ten orange trees currently exist in this portion of the property. Additional orange trees would be planted in order to fill out the orchard, and any dead trees would be removed and be replaced with new orange trees. The replacement and addition of the trees would be conducted in-kind, matching the existing type (Valencia, grafted to lemon rootstock), arrangement, pattern, and shape of the orchard and trees to retain as much feeling, appearance, and character of the historical resource as feasible.

Twenty-two new single family residences would be developed on the remaining areas of the property, each with a lot size ranging from 6,000 square feet to 8,611 square feet. Average lot size would be approximately 6,609 square feet, slightly larger than average lot sizes under the Preferred Alternative. The Historic Preservation Alternative would involve a roadway dedication of approximately eight feet along Santa Clara Avenue which would reduce the setback to five feet for the Craftsman style residence that is being retained. A connection with Lyon Street to the south and Santa Clara Avenue to the north is also included in this alternative. This alternative includes a variance for a lot frontage less than the required minimum width on Lot 12. In addition, a variance for a front yard setback less than the required 20 foot setback will be required for the Sexlinger Orchard structure. No other variances are proposed. A decorative block wall will surround the subdivision and wood fences will be used to demarcate parcel boundaries. The project is bounded roughly by East Santa Clara Avenue to the north, Portola Park on the east, East Avalon Avenue on the south, and Concord Street on the west. Photographs, plans, and maps depicting the project are attached.

Description of the Historical Resource

Based on field observations and primary and secondary source data collected in 2011 and 2012, the following is a description of the property’s major components.

The 5-acre property at 1584 East Santa Clara Avenue in the City of Santa Ana is an historic-age orchard landscape of which the major features include the remnants of a Valencia orange orchard, a residence, and a garage (McClelland et al. 1989, Revised 1999:15-18; Dolan 2009:180). The land has been historically used as an orange orchard since c. 1913, when it was

likely planted by Perry Grout, and as the Sexlinger family’s residence and orchard from 1914 to 2006. The boundary of the landscape is demarcated by the boundaries of the 5-acre parcel occupied by the Sexlinger family for 90 years. The landscape’s spatial organization has only two clusters of land uses: residential (the residence and garage) at the northwest corner of the parcel adjacent to a main thoroughfare, Santa Clara Avenue, and the orchard that fills the remaining northeast portion of the parcel.

The principal vegetation type is approximately 250 Valencia orange trees grafted to lemon rootstock; this was typical for orange groves of the region and time, due to the lemon rootstock demonstrating greater resistance to insects and disease. The trees appear to be low-headed with short trunks and pruned in the open bowl style, the common orchard tree form in the United States between 1881 and 1945 (Dolan 2009). Exact measurements were not taken as a part of the investigation; however, it appears based on a review of photographs of the trees in relation to the height of the residence and fence, that the trees are no more than 20 feet tall. The orange trees are arranged in a rectangular grid 20 rows wide (east to west) and 25 rows long (north to south). The paths between the trees, which represent the only circulation network in the landscape, are approximately 20 feet wide and 400 feet (east to west) and 350 feet (north to south) long. Between 1952 and 1980 approximately half of the trees were removed, leaving the approximately 250 trees currently present (Historicaerials.com 1952, 1972). The orchard has not been occupied since 2006. Some of the trees still bear fruit based on a review of recent photographs of the property.

The residence was built in 1914 (per Heumann and Howell-Ardila 2007 and Padon and Marvin 2008) and is a Craftsman-style single-family residence. It occupies the northwest corner of the lot and has a north-facing orientation. It is one story with a rectangular plan. The building features a low-pitch cross-gabled and hipped roof, covered with non-historic fiberglass shingles (added in 1992 per City of Santa Ana Building Permit Counter) and a brick chimney. Two gables face northward: one offset to the west and detailed with king post truss; the other centered over a squared, projecting central bay and containing a double vent flanked by knee braces. The roof terminates in overhanging eaves with exposed rafter tails and triangular knee braces. The walls are clad with redwood vertical board siding. Louvers in the gable ends have vertical laths, which are arranged in pairs on the north elevation and in pairs flanking a six-light window on the east elevation. The building has wood-frame windows, with large tripartite windows in the primary façade and double-hung sash windows on the side and rear elevations. The windows are arranged asymmetrically. Most of the windows have been covered with sheets of plywood, leaving wood frames partially visible. A cutaway porch is located on the west half on the primary façade and is supported by a square column of manufactured brick. The elevated main entry, which is located under the porch and reached via two concrete steps, is filled with the original single oak door with vertical lights and recessed panels and is covered with a modern metal security door. A rear entry on the south elevation is elevated up concrete steps and is filled with a single door with lights and recessed panels, covered with a metal security door. To the south of the residence is a detached garage. The garage is one story with a rectangular plan. It features an intersecting-gable roof covered with composition shingles. The walls are clad with horizontal board siding and there is a double-hung sash window on the south elevation. The entrance is located on the north elevation and is filled with the original sliding sawbuck door with diagonal bracing, on a metal track.

The land use, orientation of the clusters, construction materials, and design of the buildings and orchard are a response to the natural, flat topography of the area, the temperate climate that was conducive to citrus growing, and the cultural traditions of early twentieth century building in southern California. The flat topography permitted the orchard of Valencia trees, a popular and readily available crop in the area, to be planted in orderly and regularly spaced rows to the very edges of the parcel. The residence is a typical Craftsman Bungalow style home of the period, found in both rural and urban environments in southern California. Its placement beside the road, which would have been the most convenient location for a residence that was on the far outskirts of early City of Santa Ana, allowed for the most efficient use of the rest of the parcel for an orchard.

There is no evidence of landscape related archaeological resources such as road traces, ruins, or complex irrigation systems. The landscape’s constructed water features that utilize water for aesthetic or utilitarian functions in the orchard are limited to a concrete standpipe and gate valve, located approximately 50 feet south of the garage. There are no water features such as a diversion dam, diversion channel, irrigation ditches, head gates, check dams, irrigation pipes, sprinklers, water storage tanks, ponds, reservoirs, berms, and water pumps. The landscape does not retain any small-scale elements such as foot bridges, paths, road markers, gravestones, isolated vegetation, fence posts, curbstones, trail ruts, culverts, foundations, minor ruins, windmills, fruit barrels or boxes, tree ladders, tree stakes, fences, and equipment or machinery for planting, mowing, tilling, pruning, spraying, fertilizing, fruit harvesting, packing, or fruit storage. The property is now surrounding by a non-historic chainlink fence approximately five to six feet tall. There are notable views and vistas that create or allow for a range of vision in the orchard which can be natural or designed and controlled.

Significance of the Historical Resource

On June 5, 2012, the property was listed on the SARHP under Condition 6 as a building or structure that is connected with a business or use, which was once common, but is now rare. The Sexlinger residence and orange grove are associated with the development of the citrus industry in Orange County and Santa Ana in the early decades of the twentieth century. As a Valencia orange (grafted to lemon stock) farm orchard set in a rectangular grid with an associated residence and concrete standpipe and gate valve, the property is a common and simple example of the property type in southern California, but it is nevertheless a property type that is rare within the City of Santa Ana due to the conversion of most of the historic orange orchards to residential and commercial use by the mid- to late twentieth century (URS Corp 2011). Therefore, the property is listed in the SARHP under Condition (6), and is considered a historical resource for purposes of CEQA.

Impacts

The impacts of the Historic Preservation Alternative on the historical resource, as detailed by The National Park Service (NPS) National Register Bulletin 30: Guidelines for Evaluating and Documenting Rural Historic Landscapes (McClelland et al. 1999:15-17), are discussed below. The bulletin notes 11 characteristics of the rural historic landscape, which was then developed by the NPS into a list of 13 landscape characteristics that specifically apply to orchards as historical resources (Dolan 2009:178). These include: Natural Systems and Features; Spatial

Organization; Land Use; Cultural Traditions; Circulation; Topography; Vegetation; Buildings and Structures; Cluster Arrangement; Small Scale Features; Constructed Water Features; Views and Vistas; and Archaeology Sites.

The Historic Preservation Alternative would retain the following landscape characteristics:

• Land Use; • Circulation (portions of); • Cultural Traditions; • Natural Systems and Features; • Topography; • Buildings and Structures; and • Cluster Arrangement (portions of).

The property would retain its land use as a small-scale orchard and residence, although the orchard space would be much smaller. The cultural tradition of growing Valencia orange trees grafted to lemon rootstock will be retained; however, fewer trees would be in the orchard. Some of the circulation network located between the existing trees would be retained; however, a large portion of the network would be lost by new the development of the rest of the property. While the Natural Systems and Features of the land itself would not be lost, (nor would the Topography), under the Historic Preservation Alternative, neither would likely be recognizable as what exists currently. The buildings and structures –specifically, the residence and garage would remain on-site preserving their cluster arrangement; however, their overall setting and relationship with the landscape would be impaired by the construction of additional residences. However, these elements have already been impacted over time, through the extensive residential and commercial development that presently surrounds the property. Under the Historic Preservation Alternative, the extant landscape would undergo significant change as the vast majority of the orange trees of the project site would be removed and, a six-foot block wall would be constructed immediately adjacent to the house and remnant trees. New trees would be planted in-kind to fill out the parcel; however, there would be significantly less trees than what historically existed. However, the new trees would match the existing type (Valencia, grafted to lemon rootstock), arrangement, pattern, and shape of the orchard and trees to retain as much feeling, appearance, and character of the historical resource as feasible. The spatial relationship between the residence and garage, orientation of the property, and the property’s visual narrative of a small-scale orchard would be retained. Overall, the Historic Preservation Alternative does prevent demolition of the residence and garage, but the immediate setting and general environment would be impaired. Additionally, there would be some impairment of the following elements:

• Spatial Organization; • Vegetation; and • Views and Vistas.

As most of the trees on the project site would be demolished, the spatial organization would be lost. The property would be transformed from a historic single-family residence with agricultural improvements to a suburban development of 22 single family homes, with very few of the extant orange trees to remain. The property would feature the construction of new roadways, sidewalks, and residential buildings. The vegetation that currently exists would be lost, save for the small section of trees to be maintained adjacent to the location of the historic residence. 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. As Dolan writes in Fruitful Legacy, “The historic integrity of an orchard, group of fruit trees, or a single tree is a measure of physical authenticity, conveyed by extant characteristics of features that were present during the period of significance…The property must have the essential physical features that enable it to convey its historic context or historical information” (Dolan 2009:178, 190). Essentially, to remain historic by this definition, the orchard (and correlated improvements of the built environment) must maintain both its significance and its integrity. Under the Historic Preservation Alternative, the vast majority of orange trees will be removed; however, the property would still retain its key buildings and structures in their original location as well as several of the existing trees. Therefore, though the property would seem visually different than its historic appearance, it would still retain aspects of its location, design, setting, feeling, materials, workmanship, and association. Under the parameters set forth in Dolan’s Fruitful Legacy, the Historic Preservation Alternative would impact some of the physical features of the property; however, it would still convey character-defining features of its historic context and historical information from its period of significance. Under CEQA Section 15064.5, a project would potentially have significant impacts if it would cause substantial adverse change in the significance of one of the following:

(a) A historical resource (i.e., a cultural resource eligible for the CRHR); (b) An archaeological resource (defined as a unique archaeological resource which

does not meet CRHR criteria); (c) A unique paleontological resource or unique geologic feature (i.e., where the

project would directly or indirectly destroy a site or resources); or (d) Human remains (i.e., where the project would disturb or destroy burials).

CEQA Section 5020.1 defines “substantial adverse change” as the “demolition, destruction, relocation, or alteration activities that would impair the significance of the historic resource.” It further refers to the Secretary of the Interior’s Standards for Rehabilitation (Standards), that ”provide a standard guide to recommended (and not recommended) treatments to historic properties.”

Under CEQA Guidelines Section 15064.5(b)(3), a project that follows the Secretary of the Interior's Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings or the Secretary of the Interior's Standards for Rehabilitation and Guidelines for Rehabilitating Historic Buildings shall be considered as mitigated to a level of less than a significant impact on the historical resource.

The project would follow several of the Secretary of the Interior’s Standards for Rehabilitation, specifically:

• A property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces, and spatial relationships.

• The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize a property will be avoided.

• Each property will be recognized as a physical record of its time, place, and use. Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken.

• Distinctive materials, features, finishes, and construction techniques or examples of craftsmanship that characterize a property will be preserved.

• Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature will match the old in design, color, texture, and, where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.

• New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work shall be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment.

The project would also meet several guidelines that the Secretary of Interior Standards for Rehabilitation recommends for Sites and Setting, including:

• Identifying, retaining, and preserving buildings and their features as well as features of the site that are important in defining its overall historic character.

• Retaining the historic relationship between buildings and the landscape features of the setting.

• Preserving important landscape features, including ongoing maintenance of historic plant material.

• Replacing materials in-kind • Identifying retaining, and preserving building and landscape features which are important

in defining the historic character of the setting

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. As a Rehabilitation treatment, the property would receive a compatible new use that would protect and retain the property’s character defining features, historic integrity, and major buildings and structures. The property’s location, feeling, and overall character would be maintained. Surrounding the historic residence and garage with historic and in-kind replaced trees would contribute to the property’s ability to convey a specific period, time, and an agricultural past important to the community.

URS has concluded that the Historic Preservation Alternative will meet the Secretary of the Interior Standards for the Treatment of Historic Properties, thereby causing impacts to the SARHP-listed resource as being mitigated to a level of less than a significant impact to the historical resource.

This technical memorandum has been prepared in conformance with CEQA (California Public Resources Code Section 21000 et seq.), California CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.) and the applicable rules, procedures, and regulations for implementing CEQA, as adopted by the City.

Bibliography

City of Santa Ana. 2012a. “Sexlinger Farmhouse and Orchard.” City of Santa Ana website. http://www.ci.santa-ana.ca.us/pba/planning/SexlingerFarmhouseandOrchard.asp. Accessed October 3, 2012.

City of Santa Ana. 2012b “Resolution No. 2012-20” in Minutes of the Regular Meeting of the City Council of the City of Santa Ana, California, June 4, 2012. http://www.ci.santa-ana.ca.us/coc/documents/cc_minutes_20120604.pdf. Accessed October 3, 2012.

Curtis, John Obed. 1979. Moving Historic Buildings. Washington, D.C.: U.S. Department of the Interior, Heritage Conservation and Recreation Service, Technical Preservation Services Division.

Dolan, Susan. 2009. Fruitful Legacy: a Historic Context of Orchards in the United States, with Technical Information for Registering Orchards in the National Register of Historic Places. Washington D.C.: National Park Service, Olmsted Center for Landscape Preservation, Pacific West Regional Office, Cultural Resources, Park Historic Structures and Cultural Landscapes Program.

Heumann, Leslie and Deborah Howell-Ardila. 2007. Memorandum for the Record. Sapphos Environmental Inc. Prepared for the City of Santa Ana. On file at the City of Santa Ana.

Historicaerials.com. 1952, 1972. 1584 E. Santa Clara Ave., Santa Ana, CA.

McClelland, Linda Flint, J. Timothy Keller, Genevieve P. Keller, and Robert Z. Melnick. 1989, Revised 1999. National Register Bulletin 30: Guidelines for Evaluating and Documenting Rural Historic Landscapes. Washington D.C.: National Park Service.

Padon, Beth and Judith Marvin. 2008. Cultural Study Report, Empire Homes Project, (Tentative Tract Map 17231), 1584 E. Santa Clara Avenue, Santa Ana, Orange County, California. Discovery Works, Inc. and Foothill Resources, Ltd. Prepared for the City of Santa Ana. On file at the SCCIC, OR-3529.

State of California - Governor’s Office of Planning and Research, CEQA & Historical Resources. Sacramento, CA.

URS Corp. 2011. Supplemental Technical Memorandum – Cultural Resources: Eligibility Assessment of 1584 East Santa Clara Avenue, Santa Ana, California; TAVA

http://www.ci.santa-ana.ca.us/pba/planning/SexlingerFarmhouseandOrchard.asp

http://www.ci.santa-ana.ca.us/coc/documents/cc_minutes_20120604.pdf

http://www.ci.santa-ana.ca.us/coc/documents/cc_minutes_20120604.pdf

Development Project. Submitted to the City of Santa Ana, Planning and Building Agency.

Attachments

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DATE: 10-02-2012SCALE: 1" = 10 Miles (1:633,600)

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SCALE CORRECT WHEN PRINTED AT 8.5X11

OFIGURE 1: PROJECT VICINITY

SEXLINGER ORCHARD PROJECT:1584 EAST SANTA CLARA AVE.

CITY OF SANTA ANA

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SOURCES: Street Map (ArcGIS Online 2010). PROJECT LOCATIONSEXLINGER ORCHARD PROJECT

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DATE: 10/2/2012

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SOURCES: Street Map (ArcGIS Online 2010). AERIAL IMAGESEXLINGER ORCHARD PROJECT

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CHECKED BY: CM

PM: ML PROJ. NO: 29870658.10002FIG. NO:

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OSCALE CORRECT WHEN PRINTED AT 8.5X11

DATE: 10/2/2012

PLAN 1 9PLAN 2 6

PLAN 2X 7Total 22

Plan Type Number ofUnits

Jeremy_Hollins

Callout

Historic Residence and Garage to remain in place. Portion of orchard in this location to remain in place. Dead trees to be replaced in-kind.

Jeremy_Hollins

Polygonal Line

URS Corporation 3500 Porsche Way, Suite 300 Ontario, CA 91764 Tel: 909-980-4000 Fax: 909-980-1399 www.urscorp.com

June 24, 2013 Mr. Vince C. Fregoso, AICP Principal Planner Planning Division City of Santa Ana 20 Civic Center Plaza, M-20 Santa Ana, CA 92702 SUBJECT: Carbon Sequestration Greenhouse Gas Analysis for the Sexlinger Farmhouse and

Orchard Project – Santa Ana, California

Dear Mr. Fregoso

URS is pleased to submit this Carbon Sequestration Greenhouse Gas (GHG) Technical Memorandum to supplement the air quality analysis conducted for the Sexlinger Farmhouse and Orchard Residential Development Project EIR. This technical memorandum has been developed in response to public comments regarding the amount of carbon sequestration that would be lost from the change in land use from an orchard to a residential development. To address this issue, this technical memorandum discusses the amount of carbon sequestration from existing and future land development, summation of the net change in carbon sequestration with project emissions stated within the EIR and a climate change impact finding based on SCAQMD thresholds.

Proposed Project

The proposed project consists of the development and construction of 24 new single-family residences on approximately five acres, and includes the demolition of two existing structures and the removal of the trees contained in the abandoned orange grove currently on the project site. The proposed project would also widen and improve the southern portion of East Santa Clara Avenue within the project frontage and the project proposes a connection from Lyon Street south of the project site, north to East Santa Clara Avenue. The project site is located at 1584 East Santa Clara Avenue in the northeastern portion of the City of Santa Ana (City), County of Orange, California. The proposed project site is located in the Single Family Residential (R-1) zoning district with a General Plan Land Use designation of Low Density Residential (LR-7). The project proposes a vesting tentative tract map to subdivide the site into 24 parcels for single-family residences ranging in living area of 2,340 to 2,777 square feet.

Climate Change

Climate change is described as the change in climate over time. Climate change occurs due to natural variability over typically long time frames but is recently believed to be accelerated due to emissions of greenhouse gases from man-made activities. Climate change is not affected by an individual project but rather is a cumulative effect caused by emission sources on a global scale. For the state of California, the primary sources of greenhouse gases are from transportation, electricity production, as well as industrial, commercial, residential, and agricultural uses. Increasing average temperatures would affect

http://www.urscorp.com/

City of Santa Ana June 24, 2013 Page 2 of 5

California by generating more smoggy days through the contribution to ozone formation, increasing incidences of brush and forest fires, loss of 90% of the Sierra snowpack, sea level rises of more than 20 inches, greater risk of floods, and an increase in heat waves days by 3 to 4 times1.

Climate Change Legislation and Regulations

On September 27, 2006, the Governor of California signed Assembly Bill 32 (AB32), the Global Warming Solutions Act, to reduce Greenhouse Gas (GHG) emissions in California. The goals of AB32 are to reduce GHG emissions to year 2000 levels by 2010 and to 1990 levels by 2020. Executive Order S-3-05 includes an additional reduction goal: 80 % below 1990 levels by 2050. Provisions within AB32 provide CARB with the authority and responsibility to develop and enforce a GHG reduction program.

The project is located within the South Coast Air Basin (SoCAB) which is under the jurisdiction of the South Coast Air Quality Management District (SCAQMD). The SCAQMD has developed significance thresholds for a variety of air pollutants for use in CEQA (California Environmental Quality Act) documents. No official GHG threshold has been formally adopted by the SCAQMD. However, they have created a draft significance threshold which has been published in the Draft Guidance Document - Interim CEQA Greenhouse Gas (GHG) Significance Threshold. This interim CEQA greenhouse gas threshold establishes 3,000 metric tons per year as the threshold for residential developments.

Assessment Methodology

The latest emissions inventory model developed by the South Coast Air Quality Management District (SCAQMD) is the California Emissions Estimator Model (CalEEMod). CalEEMod provides emission estimates for both stationary and mobile sources for the construction and operations phases of project developments. The CalEEMod model provides quantification for carbon dioxide (CO2), methane (CH4), and nitrous oxide (N2O). This model was used to calculate the net change and carbon sequestration between the existing orchards and the proposed residential development.

CalEEMod calculates GHG emissions from vegetation according to the IPCC protocol for vegetation since it has default values that work well with the information typically available for development projects at environmental study phase of planning. The IPCC method estimates the steady-state sequestration capacity of a land use. It is also not certain that the carbon from orchards is permanently sequestered in individual trees since it is offset by the potential release of carbon from the removal of tree for replacement at the end of its useful life. But to provide a conservative analysis the orchards are assumed to result in a permanent sequestration of carbon.

A development which changes land use types results in changes in carbon sequestration from the atmosphere which would not have been captured had there been no land-use change. Overall change in sequestered CO2 is the summation of sequestered CO2 from initial land use type multiplied by area of land for the initial land use type subtracted by the summation of sequestered CO2 from the final land use type multiplied by area of land for final land use type.

CalEEMod provides two land use types to represent orchards - cropland and forest land. Cropland has an annual CO2 accumulation of 6.2 metric tons per acre whereas forest land has 111 metric tons per acre. To provide a conservative analysis, the existing orchards were represented using forest land use

1 The California Air Resources Board, Climate Change Scoping Plan a Framework for Change, December 2008.


type over the 5 acre project site. Stivers and Associates, Incorporated (Stivers) had stated in a letter (May 10, 2013) that the orchard’s sequestered carbon potentially exceeds 1300 metric tons, but does not provide any support for the basis of this value. Strivers estimate of 1300 metric tons substantially exceeds the estimate within the SCAQMD's CalEEMod by more than two and half times.

CalEEMod calculates the net change in carbon sequestration based on the existing land use and proposed vegetative cover. This net change in carbon sequestration is a one-time change that will occur when the orchard is converted to residential homes. SCAQMD has not produced clear guidance on how to incorporate these one-time emissions with the draft threshold of 3,000 metric tons. There has been some suggestion that these should be amortized over the life of the project (30 years) and added to the operational emissions. In order to be conservative since the guidance is not clear, this net change in carbon sequestration is conservatively added to the GHG emissions produced by the project and compared to the SCAQMD draft operational significance threshold to determine the degree that the project would impact climate change.

Impact Evaluation

The CalEEMod results for sequestered CO2 as shown in Table 1. As shown in Table 1, forest land (orchard) has a higher ability to sequester CO2. The result of the change in land use vegetative cover would be a loss of 555 metric tons of CO2 sequestration. When that amount of CO2 sequestration is added to the project’s GHG emissions of 507 metric tons, it results in a total project GHG emissions generation of 1062 metric tons. 1062 metric tons of GHG's is substantially less than the 3000 metric ton draft significance threshold established by the SCAQMD for residential projects. As such, project related GHG emissions with the inclusion of carbon sequestration were found to result in less than significant impacts to climate change.

Table 1 Change in Sequestered Carbon

Total CO2 (Metric Tons)

Forest land 555

EIR Emissions 507 Combined emissions (EIR + Sequestration) 1062 SCAQMD Draft Threshold 3000 Exceeds Threshold? No

Table 2 shows the total project GHG emissions if the 1300 metric ton estimate stated by Stivers was used within the impact analysis. Carbon sequestration using Stivers estimate in combination with project emissions would result in a total of 1807 metric tons of GHGs. 1807 metric tons of GHG is below the SCAQMD's significance threshold of 3000 metric tons and as such would likewise result in a less than significant impact to climate change.

Table 2


Change in Sequestered Carbon based on Stivers Sequestration Estimate

Total CO2 (Metric Tons)

Forest land (Stivers Estimate) 1300 EIR Emissions 507 Combined emissions (EIR + Sequestration) 1807 SCAQMD Draft Threshold 3000 Exceeds Threshold? No

Conclusion

The CalEEMod model was used to provide supplemental analyses of carbon sequestration for the EIR’s emissions inventory of GHGs. The impact evaluation with carbon sequestration found that total project related GHG emissions would still be below the SCAQMD’s draft screening threshold of 3,000 MTons per year even when carbon sequestration is incorporated. Because project related GHG emissions would not exceed the SCAQMD’s significance threshold, less than significant impacts would occur to climate change and no mitigation measures are necessary. This finding of less than significant impacts to climate change is consistent with the results reported within the EIR.

Should you have any questions in regards to this analysis, please do not hesitate to contact Tin Cheung at (909) 980-4000.

Sincerely,

URS CORPORATION

Tin Cheung Senior Air Quality Scientist Attachments


CalEEMod Modeling Output

1 of 8

Sequestration -

Land Use Change - 111 MT CO@/acre based on Appendix A of the CalEEMod User Guide.

Project Characteristics -

Orange County, Annual

TAVA Development Project

1.1 Land Usage

1.2 Other Project CharacteristicsUrbanization

Climate Zone

Urban

8

Wind Speed (m/s)

Precipitation Freq (Days)

2.2

30

1.3 User Entered Comments

1.0 Project Characteristics

2.0 Emissions Summary

Utility Company Statewide Average

Date: 6/26/2013CalEEMod Version: CalEEMod.2011.1.1

2 of 8

Area 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Total 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

ROG NOx CO SO2 Fugitive PM10

Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2 NBio- CO2

Total CO2 CH4 N2O CO2e

Category tons/yr MT/yr

Mitigated Operational

2.2 Overall Operational

Area 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Total 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00


Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2 NBio- CO2



Unmitigated Operational

3 of 8

3.0 Construction Detail

4.0 Mobile Detail

4.1 Mitigation Measures Mobile

4.2 Trip Summary Information

2.3 Vegetation

Vegetation Land Change

-555.00

New Trees 0.00

Total -555.00

ROG NOx CO SO2 CO2e

Category tons MT

Vegetation

3.1 Mitigation Measures Construction

4 of 8

6.1 Mitigation Measures Area

4.3 Trip Type Information

Total

Average Daily Trip Rate Unmitigated Mitigated

Land Use Weekday Saturday Sunday Annual VMT Annual VMT

Land Use H-W or C-W H-S or C-C H-O or C-NW H-W or C-W H-S or C-C H-O or C-NW

Miles Trip %

5.0 Energy Detail

6.0 Area Detail

5.1 Mitigation Measures Energy

5 of 8

6.2 Area by SubCategory

Consumer Products

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Architectural Coating

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Total 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00


Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2 NBio- CO2


SubCategory tons/yr MT/yr

Unmitigated

Unmitigated 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Mitigated 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Total NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA


Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2 NBio- CO2



6 of 8

8.1 Mitigation Measures Waste

7.1 Mitigation Measures Water

7.0 Water Detail

8.0 Waste Detail

9.0 Vegetation

6.2 Area by SubCategory

Consumer Products

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Architectural Coating

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Total 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00


Exhaust PM10

PM10 Total

Fugitive PM2.5

Exhaust PM2.5

PM2.5 Total

Bio- CO2 NBio- CO2


SubCategory tons/yr MT/yr

Mitigated

7 of 8

9.1 Vegetation Land Change

Grassland 0 / 0 0.00 0.00 0.00 0.00

Trees 5 / 0 -555.00 0.00 0.00 -555.00

Cropland 0 / 0 0.00 0.00 0.00 0.00

Total -555.00 0.00 0.00 -555.00

Initial/Final ROG NOx CO SO2 Total CO2 CH4 N2O CO2e

Acres tons MT

Vegetation Type

Unmitigated -555.00 0.00 0.00 -555.00

Total NA NA NA NA NA NA NA NA

ROG NOx CO SO2 Total CO2 CH4 N2O CO2e

Category tons MT

8 of 8

9.1 Net New Trees

Aspen 0 0.00 0.00 0.00 0.00

Total 0.00 0.00 0.00 0.00

Number of Trees

ROG NOx CO SO2 Total CO2 CH4 N2O CO2e

tons MT

Species Class

sexlinger farmhouse and orchard residential development ... · sexlinger farmhouse and orchard ....

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