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CAJA Environmental Services, LLG 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 damaged by construction and operations. Santa Ana has extensive historical and archaeological resources which heighten the risk of impacts from new construction. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance "only affects existing structures" and therefore, there would be no change in cultural resources impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 27.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of cultural resources impacts is insufficient, finding that the STR ban would only "affect existing structures" and "construction activities would not occur." (Staff Report, Exhibit 3, p. 27.) This analysis lacks any consideration of the reasonably foreseeable construction of new hotels from an STR ban, which could result in potentially significant impacts to cultural resources, as discussed below. Construction and Operation of New Hotels The construction and operation of new hotels has the potential to result in significant environmental impacts with respect to cultural resources. Cultural resources, including historical resources, archaeological resources, and human remains, could be damaged by construction and operations. Hotels currently exist near, or may be a component of, existing designated cultural resources in urban locations in the City. As discussed above, the City has identified certain locations in its General Plan, various Specific Plans, and Zoning Code appropriate for hotels. The expansion or construction of hotels in these locations could have potential to significantly and adversely harm historically important cultural resources and undetected cultural resources covered by topsoil and require mitigation. This is particularly true given the extensive cultural and historical resources within Santa Ana. As discussed in the Addendum's discussion of the GP PEIR, "there are eight archaeological resources" recorded in the City, including four prehistoric sites, one multicomponent site, and three historic isolates, and that development involving ground disturbance in the City has potential to impact known and unknown archaeological resources. (Staff Report, Exhibit 3, p. 24.) According to the GP PEIR, "Existing Conditions Database reveals approximately 2,511 historical resources have been recorded in Santa Ana. ))24 Further, "the California Historical Resources Information System records search indicates that 23 archaeological resources were previously recorded within 0.5 mile (0.8 km) of the [General Plan] area.25 And, importantly: While the review of ethnographic and historical maps does not indicate the presence of any specific Native American archaeological resources, the proximity of mapped locations of settlements in the vicinity of the plan area indicate a high sensitivity. The presence of the Santa Ana River, a permanent water source that connects the closest mapped Native American villages, and numerous springs mapped throughout the area on the rancho plat maps indicate that there is likely a high sensitivity for Native American archaeological resources throughout the 24 City of Santa Ana, GP EIR, p. 5.4-26 (Dec. 2023), available here. 25 Id., p. 5.4-18. 17