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CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 significance). Mitigation measures, if feasible, could be needed to reduce indirect impacts to less than significant. Absent any feasible mitigation, impacts to historical resources could be significant. Archaeological Resources With respect to archaeological resources including human remains, there is always the possibility that such resources are uncovered during construction activities for hotel construction. The City's General Plan includes Objective 3.1 to "[m]inimize loss of natural aesthetic, historic, archeological, and paleontological resources as land is developed." The likelihood of discovering such resources depends on a number of factors, including: 1) whether a site has previously been developed; 2) the extent of excavation for any prior development; 3) the extent of excavation for the current construction (such as whether any subterranean levels would be included); 4) the types of soils at a site; and 5) whether the site is in a location of known archaeological sensitivity. Depending on the specific conditions of a site, mitigation measures may be necessary to reduce impacts with respect to archaeological resources to less than significant. Given the reasonable foreseeability of new hotel development resulting from an STR ban, the City must study whether there are cultural resources present in locations where it is reasonably foreseeable these new hotels will be built. Cultural Resources Mitigation Measures from the GP PEIR are Inapplicable The City cannot rely on the cultural resources mitigation measures from the GP PEIR to address these potentially significant impacts because, as discussed above, the Proposed Ordinance is a separate project and cannot be addressed through an Addendum to the GP PEIR and, therefore, the mitigation measures from the GP PEIR cannot be applied to this new project. Ener Overview As discussed in detail in the technical environmental analysis prepared by Ramboll, an STR ban can reasonably be expected to cause significant energy impacts for several reasons including: (1) relocating existing STR guests to less efficient hotels and other replacement facilities that recent reports indicate use more energy per guest; and (2) stimulating replacement accommodation construction and expansion that will increase energy demand related to new material manufacturing, transportation and installation, heavy equipment use, and maintenance, which use electricity and transportation fuels (primarily gas and diesel). Ramboll concluded that the STR ban would increase energy demand because hotels use more energy per person than STRs and would also increase demand for fossil fuels due to increased VMT, inconsistent with regional and state climate policy. (Ramboll Environmental Analysis, pp. 7-8.) The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the STR ban would not result in any "construction -related energy consumption" or "any physical impacts to the environment" and that there would be no new or more severe significant energy impacts beyond any identified in the GP PEIR. (Staff Report, Exhibit 3, p. 28.) This is inadequate. 19