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City of Santa Ana <br />Impact Statement Impact Summary Findings <br />Impact 4.2-E1: Development of the Elan <br />Project would result in a substantial adverse <br />change to a historical resource. <br />Impact 4.2-E2: Implementation of the Elan <br />Project has the potential to cause a substantial <br />adverse change in the significance of an <br />archaeological resource pursuant to Section <br />15064.5 of the State CEQA Guidelines, and this <br />would be considered a significant impact. <br />Impact 4.2-E3: Implementation of the Elan <br />Project has the potential to directly or indirectly <br />destroy a unique paleontological resource or <br />site or a unique geologic feature, and this would <br />be considered a significant impact. <br />Because the proposed Elan Project would <br />demolish the Santa Ana Elks Lodge, it would <br />result in a substantial adverse change to a <br />historical resource. <br />The Elan Project area has low overall sensitivity <br />for prehistoric or historic archaeological <br />resources, though it is possible that deeper <br />cultural deposits could be present below <br />surface sediments. Construction activities <br />would involve excavation well below surface <br />sediments, and could thereby disturb <br />prehistoric archaeological remains and other <br />cultural deposits. Therefore, the Elan Project <br />has the potential to cause a substantial adverse <br />change in the significance of an archaeological <br />resource. <br />The Elan Project area has high paleontological <br />sensitivity. Activities associated with the Elan <br />Project, including excavation for and <br />construction of two levels of underground <br />parking, have the potential to result in direct or <br />indirect destruction of a unique paleontological <br />2. CEQA Findings <br />Findings 1 and 3. No additional feasible <br />mitigation is available. <br />Implementation of mitigation measures MM - <br />CUL -2 through MM -CUL -4 would reduce <br />potential impacts but not to a less -than - <br />significant level. Because the proposed Elan <br />Project would demolish the Santa Ana Elks <br />Lodge, it would result in a substantial adverse <br />change to a historical resource. The Santa Ana <br />Elks Lodge property cannot be relocated or <br />preserved. Therefore, there are no mitigation <br />measures to reduce this impact to a less -than - <br />significant level, and impacts would be <br />significant and unavoidable. <br />Finding 1. Changes or alterations have been <br />required in, or incorporated into the project <br />which avoid, substantially lessen, or reduce the <br />magnitude of the significant environmental <br />effect. <br />Implementation of mitigation measures MM -OZ <br />4.4-2 and MM -OZ 4.4-3 from the MEMU EIR <br />would ensure that any impacts on the <br />significance of an archaeological resource <br />would be reduced to less than significant. <br />Finding 1. Changes or alterations have been <br />required in, or incorporated into the project <br />which avoid, substantially lessen, or reduce the <br />magnitude of the significant environmental <br />effect. <br />resource. Implementation of mitigation measure MM - <br />CUL -1 would ensure that potential impacts on <br />Metro East Mixed -Use Overlay District Expansion and Elan August 2018 <br />Development Projects 2-14 ICF 19.18 <br />Findings of Fact/Statement of Overriding Considerations <br />