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ARROYO LAGO RESIDENTIAL PROJECT ADDENDUM FCS 97 Https://adecinnovations.sharepoint.com/sites/PublicationsSite/Shared Documents/Publications/Client (PN-JN)/2148/21480036/Addendum/21480036 Arroyo Lago Residential Project Addendum.docx impacts or create substantially more severe significant impacts than those previously identified in the Prior FEIR. No additional analysis is required. d) Listed or Eligible Tribal Cultural Resources Would the project: Cause a substantial adverse change in the significance of a Tribal Cultural Resource, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American Tribe , and that is listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k)? Prior FEIR Conclusions The Prior FEIR detailed that records search results from the NWIC indicate that three historic resources are located within 0.5 mile of the project site and the limit of disturbance areas, and a review of the NAHC Sacred Lands File search was negative for recorded TCRs within the project site. Consistent with requirements under CEQA, a letter containing project information requesting any additional information and consultation regarding TCRs was sent to each Tribal representative on February 27, 2023. No responses were received. As of the writing of the Prior FEIR, no TCRs listed or eligible for listing were identified within the project site. Nevertheless, inadvertent discovery of TCRs is always possible. Should TCRs be discovered during ground disturbance activities, implementation of MM CUL-2a, MM CUL-2b, and MM CUL-3 would reduce potential impacts on TCRs to a less than significant level. Therefore, the Prior FEIR concluded that impacts would be less than significant with mitigation incorporated. (Draft EIR, pp. 3.4-28, 6-14). Proposed Project Analysis and Conclusion Because the proposed project would be constructed in the same location as the County Project, the results of the record searches and the pedestrian field survey conducted under the Prior FEIR would still apply. However, the proposed project would reduce the overall scope and nature of off-site improvements compared to the County Project, reducing the area where TCRs could be affected. On February 18, 2026, the City sent out Tribal consultation letters pursuant to Senate Bill (SB) 18, which requires Tribal consultation for projects proposing a General Plan Amendment, to identify additional significant TCRs meeting the criteria set forth in subdivision (c) of the Public Resources Code Section 5024.1.27 Tribes have 90 days to respond and request consultation, (i.e., until May 18, 27 Assembly Bill (AB) 52 consultation requirements under Public Resources Code §21080.3.1 apply to projects subject to CEQA that may affect Tribal Cultural Resources (TCRs); however, Section 21080.3.1(a) applies only to negative declarations, mitigated negative declarations and environmental impact reports and is not applicable to this addendum. Therefore, AB 52 consultation is not required for this addendum. In contrast, SB 18 consultation requirements under Government Code Section 65352.3 apply to adoption or amendment of a general plan. Because the proposed General