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iCAJA Environmental Services, LLC 9410 Topanga Canyon Blvd.,Suite 101 Chatsworth,CA 91311 Phone 310-469-6700 Fax 310-806-9801 resources impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 23.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of biological resources impacts is insufficient, finding that the STR ban would "only affect existing structures," and "is not anticipated to result in physical impacts to the environment." (Staff Report, Exhibit 3, p. 23.) 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 biological resources. Construction of New Hotels Direct impacts to biological resources may occur if new hotels are constructed on land that contains protected species, wetlands, jurisdictional waters, special status plant or animal communities, species migration corridors (including migratory birds), and habitat conservation areas. As discussed above, the City's General Plan, various Specific Plans, and Zoning Code have identified certain locations in the City appropriate for hotels. The City has not evaluated the potential for these areas to have protected habitat, so it is unknown whether development in these areas would fragment key habitat,for example, or otherwise interfere with special status plant or animal communities. This needs to be evaluated in a full EIR. The Conservation Element of the City's General Plan identifies as Goal CN-2: Natural resources, the goal of preserving and enhancing "Santa Ana's natural and environmental resources while maintaining a balance between recreation, habitat, restoration and scenic resources.,22 Policy CN-2.1 is aimed at preservation of biodiversity and provides for collaboration "with State and County agencies to promote biodiversity and protect sensitive biological resources."23 Failure to analyze the potential impacts to biodiversity from construction of new hotels is inconsistent with the City's General Plan. The construction and operation of new hotels in locations that physically and directly affect these resources by, for example, removing habitat such as trees, or that have substantial indirect effects, such as dust, noise and vibration, light, trash, vehicle use, and other anthropogenic activities in close proximity with high- value habitats or migration routes, would have significant impacts and require the imposition of all feasible mitigation under CEQA. The City failed to analyze whether development of new hotels may occur on any such lands, and if so, what mitigation measures, if feasible, would need to be provided to reduce impacts to less than significant. Absent any feasible mitigation, impacts to biological resources could be significant. Cultural Resources Overview An STR ban may significantly impact cultural resources from the reasonably foreseeable construction and operation of new hotels to accommodate patrons who would have previously utilized STRs. Cultural resources including historical resources, archaeological resources, and human remains, could be 22 Santa Ana General Plan, Conservation Element, CN-09. 23 Ibid. 16