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Responses to Comments on the EIR Addendum As discussed in Response 14, a Cultural Resources Study was conducted for the project in April 2019 in accordance with CEQA and is included as Appendix C to the Addendum. The Cultural Resources Study was specifically prepared in accordance with the requirements of Mitigation Measure 4.4-3 from the 2010 FEIR and guidelines outlined by the Office of Historic Preservation. An independent CHRIS records search was not completed for the current project due to "constraints surrounding COVID-19" given the adequate coverage provided by the previous searches. However, other efforts included background and archival research, a Native American Heritage Commission (NAHC) Sacred Lands File (SLF) search, a field survey of the project site, the evaluation of one property for historical significance, and a discussion of potential project -related impacts which found that no new impact to historic resources would occur. Response 16 The commenter states that, since the City failed to implement mitigation measures required by the 2010 FEIR, the City has failed to proceed in a manner required by law and a subsequent EIR is required. The commenter specifies that the project would have significant impacts to a historic resource and, because the City failed to comply with mitigation measures required by the 2010 FEIR, a supplemental EIR is required to analyze the project. As described in Response 1, the project did not require a subsequent or supplemental EIR or negative declaration because none of the conditions described in PRC Section 21166 and CEQA Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Section 3, EnvironmentallmpactAnalysis, of the Addendum supports the conclusion that changes to the project would not result in new or more severe impacts and includes applicable mitigation measures identified in the 2010 FEIR. Appendix K to the Addendum includes the MMRP of the 2010 FEIR for reference to applicable mitigation measures. Furthermore, as discussed in Response 14, the Santa Ana Car Salon is ineligible for listing in the NRHP, CRHR and on the City of Santa Ana RHP and does not qualify as a historical resource as defined by CEQA. The project would not result in a new or significant impact to historic resources. Response 17 The commenter states that, in addition to the historic resources mitigation measure in the 2010 FEIR, the City failed to implement mitigation measures related to energy conservation, greenhouse gas emissions, and air quality. The commenter specifies that the 2010 FEIR requires projects to exceed Title 24 energy standards by 20 percent, whereas the project would only comply with Title 24 and not exceed it. The commenter restates that, because the City failed to comply with mitigation measures required by the 2010 FEIR, a supplemental EIR is required to analyze the project. As discussed in Response 14, the Santa Ana Car Salon is ineligible for listing in the NRHP, CRHR and on the City of Santa Ana RHP and does not qualify as a historical resource as defined by CEQA. Therefore, the project would not have an impact to historic resources and no mitigation is required. As described in Response 1, the project did not require a subsequent or supplemental EIR or negative declaration because none of the conditions described in PRC Section 21166 and CECIA Guidelines Sections 15162 and 15164 were met to trigger the need for these documents. Section 3, Environmental Impact Analysis, of the Addendum supports the conclusion that changes to the project would not result in new or more severe impacts related to energy conservation, greenhouse gas emissions, and air quality and includes applicable mitigation measures identified in the 2010 75C-293