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Page 11 of 27 HRAC did not properly analyze the Project’s effects on the “cluster of historic buildings” that are on the affected block (i.e. 612 Jefferson, 605 Middlefield, and 611 Middlefield). (See Appeal, pp. 1-8) City Response: The City properly considered historic resources, community preferences for structures that reflect the character of the area’s historic architecture, and whether the Project will detract from adjacent historic resources. To specifically address these issues, this report outlines how the Project complies with all historic preservation provisions as well as all mitigation measures of the DTPP which apply to non-historic sites (such as the subject site) that are adjacent to historic resources. First, as described in the Planning Commission report, the Project complies with all historic preservation measures. The historic resources regulations are placed first in order in Book 2 (Development Regulations) of the DTPP because they are of particular interest. However, they do not trump any other regulations. Rather, they are interrelated to and complementary with the other regulations of Book 2. In preparing the DTPP, every property in the larger downtown area (approximately 183 acres) was studied and all historic resources were identified. (DTPP, p. 153) As noted in the Background section above, extensive outreach was conducted in the course of preparing the DTPP. Forty properties were found to have very high historic significance, and were identified as “Resources to be Preserved” (depicted in red on the Historic Resources Preservation Regulations Map on p. 30 and the Historic Resources Reconnaissance Survey Map on p. 153.) An additional seven resources that contain low significance, integrity and context were also identified and labeled as “Resources which may be Altered, Relocated or Removed” (depicted in brown on the same maps). The Project site itself does not contain any historic resources; however, it is located adjacent to three historic resources: 620 Jefferson Ave., 605 Middlefield Rd., and 611 Middlefield Rd. Of these three properties, 620 Jefferson Ave. and 611 Middlefield Rd. are identified in the DTPP as Historic Resources to be Preserved, and 605 Middlefield Rd. is a Historic Resource which may be Altered, Relocated, or Removed. Appellants contend that this constitutes a cluster of historic resources that the Project will negatively impact, and therefore the Project is inconsistent with the DTPP’s historic resource preservation regulations. The regulations and evidence are to the contrary. In crafting the DTPP, the City identified areas with strong clusters of historic resources where adjacent, non-historic sites would be subject to development restrictions in order to “minimize visual impacts on historic buildings as much as possible and to preserve the historic urban feel of the area within a framework of new development.” (DTPP, p. 152) Examples of such areas where clusters of historic resources are located include Broadway and Main Street. In those areas, non-historic properties near historic properties are subject to further development restrictions. Relative to those areas, the North of Marshall District, where the Project site is located, has few historic resources 8.A. - Page 11