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Correspondence - PH #35
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Correspondence - PH #35
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City Clerk
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35
Date
11/19/2024
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CAJA Environmental Services, LLC <br />9410 Topanga Canyon Blvd., Suite 101 <br />Chatsworth, CA 91311 <br />Phone 310-469-6700 Fax 310-806-9801 <br />guests of STRs transitioning to using hotels. (Ramboll Environmental Analysis, p. 4.) NOx <br />causes adverse health consequences including breathing difficulties and increased risk of <br />chronic pulmonary fibrosis as well as bronchitis in children. PM2.5 can damage the <br />respiratory tract, increasing the number and severity of asthma attacks, and aggravating <br />bronchitis and other lung diseases, and reducing the body's ability to fight infections. <br />(Ramboll Environmental Analysis, p. 3.) Ramboll further concluded that the STIR ban would <br />disproportionately burden environmental justice communities because the City's <br />communities most burdened by regional pollution and localized traffic exposure are located <br />near the existing hotel stock and would be directly impacted by increased hotel usage in <br />response to the STIR ban, increasing the known pollution contributors to respiratory and <br />cardiovascular health risks in these communities. (Ramboll Environmental Analysis, pp. 5- <br />7.) Ramboll concluded that the STIR ban could increase traffic concentrated on roadways <br />going to the hotels in the City by 7,560 vehicles per day, resulting in health impacts that <br />would exceed the SCAQMD CEQA threshold of significance for cancer risk. (Ramboll <br />Environmental Analysis, pp. 8-9.) Further, Ramboll concluded the construction of new <br />hotels without emissions mitigation would result in an excess cancer risk of 48 in a <br />million for the maximum exposed individual — exceeding by more than 4 times <br />SCAQMD's threshold of 10 in a million. (Ramboll Environmental Analysis, p. 11.) <br />o GHG Emissions. Ramboll concluded that the STIR ban would result in an increase of <br />daily mobile emissions of GHG by 443 percent, contributing to a significant increase in <br />emissions in the area in direct conflict with regional and state goals to reduce VMT and <br />GHG emissions from vehicle trips. (Ramboll Environmental Analysis, p. 4.) Further, <br />Ramboll concluded that the increased energy demand associated with hotels compared to <br />STRs would result in a 179 percent increase in GHG emissions per person. (Ramboll <br />Environmental Analysis, p. 8.) <br />o Energy. Ramboll concluded the STIR ban would increase energy demand because hotels <br />use more energy per person than STRs (more than 5x more electricity, more than 2x <br />more natural gas). (Ramboll Environmental Analysis, pp. 7-8.) By increasing VMT, the <br />STIR ban would also increase reliance on fossil fuels to power vehicle trips —the daily <br />mobile fuel consumption for hotels is more than five times greater for hotels compared to <br />STRs for both gasoline and diesel —inconsistent with regional and state climate goals. <br />(Ramboll Environmental Analysis, p. 8.) <br />o Transportation. Ramboll concluded that the STIR ban would increase the number of trips <br />taken by guests to and from hotels, more than doubling the trips per day compared to <br />STRs. (Ramboll Environmental Analysis, p. 4.) As discussed herein, this increase in trips <br />would result in air quality and health risk, GHG emissions, energy, and noise impacts. <br />Further, Ramboll concluded the STIR ban would concentrate traffic by increasing traffic <br />by 7,560 vehicles per day on road to the City's hotels, resulting in health risks <br />exceeding SCAQMD3s CEQA threshold of significance for cancer risk. (Ramboll <br />Environmental Analysis, p. 9.) <br />3 <br />
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