"SunCal proposes to write its own Historic Resources Design Guidelines (HRDG) and it is unclear if the Guidelines would include Standards set by the Secretary of the Interior. The proposed approval processes for alteration or demolition of historic resources, as included in the Initiative, are often too broad, easily subject to abuse and the boundaries of the Preservation Mixed Use area are not shown consistently within their own Specific Plan."

"Many historic structures will fall outside the Initiative’s new Historic District boundary. It is not clear the re-defined historic district would continue to be eligible for the National Register of Historic Places, [and] the remaining buildings might no longer qualify for the 20% federal tax credit for improvements to historic buildings. This could make rehabilitating those buildings economically unfeasible."