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CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 Reliance on an Addendum to the GP PER is Inappropriate The Proposed Ordinance is a new project, completely unrelated to the City's adoption of its General Plan, so the City's reliance on an addendum or any other subsequent, supplemental, or tiered analysis based on the GP PER would violate CEQA. The General Plan makes no reference to STRs, does not in any way evaluate existing operations of STRs, or indicate that STRs will be prohibited in the City. As a new, distinct project, it is not appropriate to prepare an addendum to an existing environmental impact report ("EIR") when that prior EIR did not previously review or even contemplate the scope of the current project or related environmental concerns, and the new project introduces changes that are substantial, requiring new environmental review. (Mantis Camp Community Association v. County of Placer (2020) 53 Cal.App.5th 569, 606 n.26 [emphasis added]; see also Friends of College of San Mateo Gardens v. San Mateo County Community College Dist. (2016) 1 Cal.5th 937, 950 [CEQA's "subsequent review provisions ... have no application if the agency has proposed a new project that has not previously been subject to review."].) Friends of College of San Mateo Gardens held that in order for a lead agency to rely on a previously certified CEQA document, that document must "retain informational value" as to the new project. (Friends of College of San Mateo Gardens v. San Mateo County Community College Dist. (2017) 11 Cal.App.5th 596, 605.) Here, because the GP PER did not mention let alone analyze STRs in any way, and certainly did not analyze the impact of banning STRs it retains no informational value as to the Proposed Ordinance. Specifically, there is no substantial evidence that the GP PER retains informational value to analyzing the Proposed Ordinance because: (1) the GP PER traffic analysis did not consider STRs and therefore provides no informational value on the STIR ban's reasonably foreseeable increases to VMT or congestion as visitors are forced to travel greater distances to regional commercial centers to find available or affordable hotels or allowed STRs; (2) the GP PER air quality and GHG analysis did not consider STRs and therefore provides no informational value on the STIR ban's reasonably foreseeable increases of air pollutants caused by the increase in VMT (and the corresponding health impacts from those pollutant increases) and increasing GHG emissions caused by the increase in VMT (and related inconsistencies with local, regional, and state climate plans); (3) the GP PER noise analysis did consider STRs and therefore provides no informational value on the STIR ban's reasonably foreseeable noise impacts caused by increased traffic congestion and construction that is reasonably foreseeable from the STIR ban; and (4) other topic areas, as documented in this letter, where the record is bereft of information pertaining to the important environmental issues that must be analyzed under CEQA to asses and disclose the environmental consequences of this action. In contrast to the GP PEIR's prior lack of analysis, our analysis below, and the technical environmental and economics reports from Ramboll Americas Engineering Solutions, Inc. ("Ramboll"), submitted concurrently with and relied upon in this report, demonstrate that there are numerous reasonably foreseeable impacts, including: • Direct impacts from the STIR ban caused by increases in VMT, air pollutants, energy use, GHG emissions, and noise: o Air Quality. Ramboll concluded that the STIR ban would result in an increase in daily mobile emissions of approximately 443 percent of NOx and 444 percent of PM2.5 from 2