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But these regulations do not control development on 601 Marshall Street. For example, <br />there are no architectural review standards or guidelines limiting the height of buildings <br />adjacent to 620 Jefferson Avenue (other than the standard height limitations of buildings <br />to 12 stories, as discussed elsewhere in this report). <br /> <br />Thus, the Project is in compliance with all historic preservation provisions. <br /> <br />Second, the Project is in compliance with all measures of the DTPP which apply to non- <br />historic sites (such as the subject site) that are near historic resources. <br /> <br />All non-historic parcels in downtown, including the Project site, are placed into non- <br />historic mitigation groups ranging from 1 to 6, with group 1 having the most mitigation <br />measures and group 6 having the least. (DTPP, p. 31 [Historic Resources Preservation <br />Chart].) The groups have mitigation measures, or development restrictions, meant to <br />minimize impacts to the nearby historic resource. A portion of the Project site adjacent <br />to 611 Middlefield is within non-historic mitigation group 4, which includes height <br />reductions along its frontage. The remaining portions of the Project site are within non- <br />historic mitigation group 6, which requires review by an architectural historian and the <br />HRAC. <br /> <br />As a result, the City was required to review the Project for any potential “substantial <br />adverse change” to the three adjacent resources—the historic courthouse, 611 <br />Middlefield Road and 620 Jefferson Avenue. (DTPP, p. 43 [2.1.4(D)].) The Applicant <br />hired Richard Brandi, a qualified architectural historian, to review the potential impacts <br />to the significance of 611 Middlefield Road and 620 Jefferson Avenue. The City hired <br />Page & Turnbull, qualified architectural historians, to peer review Mr. Brandi’s analysis <br />and to analyze potential impacts to the significance of the historic courthouse. The <br />reports explain that the Project, even at its original proposed height of 11 stories, would <br />not cause a “substantial adverse change” to the significance of these three historical <br />resources and that these resources would retain their continued eligibility for listing on <br />the California Register. The HRAC and the Planning Commission relied on these <br />reports to conclude that the Project would not cause a substantial adverse change to <br />the significance of these three historical resources, as required by the DTPP (Section <br />2.1.4.D) and the certified EIR mitigation measures. Page & Turnbull prepared a <br />subsequent memo, dated August 7, 2015, that analyzed the reduced 9-story Project, <br />that again concluded that the Project will not cause a substantial adverse change to the <br />significance of the three adjacent historic resources. Thus, the Project is in compliance <br />with all required non-historic mitigation measures that apply to the Project site at 601 <br />Marshall Street. <br /> <br />7.A. - Page 10