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drCAJA Environmental Services, LLC 9410 Topanga Canyon Blvd.,Suite 101 Chatsworth,CA 91311 Phone 310-469-6700 Fax 310-806-9801 impacts to tribal cultural resources beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 47.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of tribal cultural resources impacts is insufficient, finding that the STR ban would only affect existing structures and there would be "no earthwork or ground-disturbing activities." (Staff Report, Exhibit 3, p. 47.)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 tribal cultural resources, as discussed below. Construction and Operation of New Hotels The presence of tribal cultural resources in Santa Ana are discussed above in the Cultural Resources section. The same issues applicable to the potential for disturbance of cultural resources as a result of construction of new hotels apply to tribal cultural resources. As discussed above in the Cultural Resources section, tribal cultural resources that could be present in Santa Ana include Native American burial sites, village or occupation sites, and traditional resource- gathering locations. For example, the Gabrielino (or Tongva and Kizh), Juaneno (or Acjachemen), Luiseno peoples inhabited the region and there may be tribal cultural resources present in the sites for new hotel development that must be surveyed.49 In addition, AB 52 establishes a formal consultation process for California Native American Tribes to identify potential significant impacts to tribal cultural resources. Depending on the specific conditions of a site, as well as the results of tribal consultation conducted pursuant to AB 52, mitigation measures may be necessary to reduce impacts with respect to tribal cultural resources to less than significant. The City must conduct tribal consultation in compliance with SB 18 and AB 52. Utilities/ Service Systems Overview The prohibition of STRs is reasonably likely to significantly impact utilities and services systems by increasing demand for water, electricity, natural gas, and increased generation of wastewater and solid waste.As discussed above, a 2018 Cleantech analysis found that when guests stay at an STR, significantly less energy and water is used, greenhouse gas emissions are lower, and waste is reduced, compared to hotel stays50 and an article published in the Small Business Institute Journal also proposed that sharing economy based accommodations are likely to consume less energy and water, and produce fewer GHG emissions and less waste, than traditional accommodations.51By increasing demand for these services 49 Michael Baker International, Tribal Cultural Resources Identification Memorandum for the South Coast Technology Center Project, City of Santa Ana, Orange County, California, p. 6 (Apr. 2024). so Airbnb, How the Airbnb Community Supports Environmentally-Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide. 51 Midgett et al., The Sharing Economy and Sustainability:A Case for Airbnb, 13 SMALL BUSINESS INST.J. 2, pp. 61- 63 (2017). 33