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7A <br /> Page 19 <br /> impacts that may warrant fixrther mitigation measures,or changes to the proposed <br /> project".We therefore stand by our original conclusions and request that the Ciry <br /> . prepare an EIR ta address the issue of aesthetic impacts from this projec� <br /> 6.5 Culturat Resources(a}--�Cause a substantia.i adverse change ua the s�ignificance <br /> of a historical resource as defned in§154b4.5?" . <br /> Recap <br /> In our submitted IS/MND comments,we canctuded that fhe cul#ural resou�ces evaiva.tion <br /> conducted for the Initial Sfudy was inadequate because it lacked an appropriate historic <br /> context evaivation.The missing contextual data resuits in an inadequate description of <br /> t�e��viro�mentai sei�ing�equired hy CEQA as a baseline to deterrn�ne project imp�.cts. � <br /> We pointed out#hat such an evaluation was warrant�d far the project becaus�: <br /> a) the Ci�'s historical consultant tSheila McElroy,CIRCA)vvho revzewed the <br /> reports,identified the context informatian as inad�quate and,in both her review <br /> letters and in testimony to the HRAC,carnmented on tbe importance of an <br /> �� apprapriate context evatu.ation in assessing whether the proposed.project m�ay <br /> have a signif cant impact, <br /> b) the historic el�m�nt of the eity's current General Plan identified the Ariington <br /> neighborhood,which inciudes the Finger Park"�r�.ct,as containing many <br /> histarieal buildings a�d may have potential fvr.containiug an his�oric district. <br /> Thus,even if the individual sbruc�axes at S0, 8U,and 88 Finger may not be <br /> historically significan#with respect to theix particular architectural styles or <br /> assaciation wzth i�ngortant persons,their.destruction may result in a sig�.uficanic <br /> impact ta a broader view of the histarie signifcanc�of f.he neighborhood(the <br /> extent of which has yet to be defined). <br /> The City's response appeared to interpret our cnmments as an attem}at to show that the <br /> Finger Avenue neighborhood const�tuted an historic district and poiup�ted out that we had <br /> not provided substantial evidence tu prove�.b.at the neighborhaod warranted historic <br /> district status.The City alsa suggest�d that we had tried to mislead the Commi�sian with <br /> respect to Ms McElroy's commen#s by stating that Ms.McEtroy's reviews clid not apply <br /> to t�e fuzal dra�t of the cultural evaluation report. <br /> At the Feb. 1 Q hearing,we clarified our position in regard�o tl�.is issue.VV41"e made it clear <br /> that: <br /> a) the Ciiy's review of the Applicant's cultural resources�valuation was no�,in fact,a <br /> peec review,b�t mer�ly a"completen�ss"review: <br /> b} our representation of Ms.�cE�roy's comments were correct,white her review <br /> pertained to an earlier submitted addendum,the historie contex#evaluation included <br /> in the report ac�opted by the HRAC was word-fvr-word iden�ical to the text that Ms. <br /> McElroy cri�icized as inadequa.tc. <br /> c) we were nvt c�aimang that the neighborhood constitutes an historic disiriet;there i.s <br /> insuf�icient information at present ta eva.lua�tihat.'�hat we are cla.��is,based <br /> upon informarion in th�tustoric element of�he general plan,and the opvfion of the <br /> City's own consultant,there is substannal evidence for�he poten�ial for destruction <br />