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The City of Santa Ana is proposing to approve the Project without review under the California Environmental Quality Act (“CEQA”), Pub. Res. Code section 21000, et seq., based on the assertion that the Project is consistent with the 1983 Fashion Square Commercial Center Subsequent Final Environmental Impact Report (“1983 EIR”), which was certified in 1983. The City contends that under CEQA Guidelines sections 15162 and 15164, no further environmental review is required. PROJECT DESCRIPTION The Project involves adoption of a specific plan to facilitate the redevelopment of the existing MainPlace Mall into a regional, mixed-use village with additional commercial, office, residential, and hotel projects. The Project involves 1,400,000 square feet of commercial, 750,000 square feet of office, 400 rooms of hotel, and 1,900 residential units. The Project site currently contains the 1,130,000 MainPlace Mall regional shopping center, three parking structures, and surface parking lots. The site is approximately 49 acres and is located northeast of the corner of Main Street and Main Place Drive. It is surrounded by the Santa Ana (I-5) Freeway to the west, the Garden Grove (SR-22) Freeway to the north, Main Street and commercial and mixed-use land uses to the east, and Main Place Drive and commercial-office land uses to the south. A midrise office building is located adjacent to the site at 2700 North Main Street. A. LEGAL STANDARD CEQA contains a strong presumption in favor of requiring a lead agency to prepare an EIR. This presumption is reflected in the fair argument standard. Under that standard, a lead agency must prepare an EIR whenever substantial evidence in the whole record before the agency supports a fair argument that a project may have a significant effect on the environment. (Pub. Res. Code § 21082.2; Laurel Heights Improvement Ass’n v. Regents of the University of California (1993) (“Laurel Heights II”) 6 Cal. 4th 1112, 1123; No Oil, Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 75, 82; Quail Botanical Gardens v. City of Encinitas (1994) 29 Cal.App.4th 1597, 1602.) The City relies on CEQA Guidelines § 15162 and 15164 to claim that no CEQA review is required. The court of appeal recently stated, “The addendum is the other side of the coin from the supplement to an EIR. This section provides an interpretation with a label and an explanation of the kind of document that does not need additional public review.” “It must be remembered that an addendum is prepared where ‘(2) Only minor technical changes or additions are necessary to make the EIR under consideration adequate under CEQA; and (3) The changes to the EIR made by the addendum do not raise important new issues about the significant effects on the environment.’ ([Guideline] 15164, subd. (a).) Save Our Heritage Organization v. City of San Diego , 28 Cal. App. 5th 656, 664–65 (2018) (emphasis added). Section 15164(a) of the State CEQA Guidelines states that “the lead agency or a responsible agency shall prepare an addendum to a previously certified EIR if some changes or additions are necessary, but none of the conditions described in Section