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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 o Noise. Ramboll concluded the STR ban could concentrate traffic on roadways going to hotels in the area, since many hotels in the City are located in one concentrated area of the City, resulting in noise impacts above the City's General Plan Noise Element standard of 65 dBA CNEL, potentially exacerbating existing noise impacts or creating a new significant noise impact. (Ramboll Environmental Analysis, pp. 9-10, 13-14.) • Indirect impacts stemming from the ban's reasonably foreseeable result of new hotel space construction. Ramboll estimates the STR ban will cause potentially significant new impacts related to hotel construction including air quality and health impacts from construction emissions including diesel particulate matter, and noise impacts exceeding the City's General Plan Noise Element standard and the City's noise ordinance. (Ramboll Environmental Analysis, pp. 11-12.) • Cumulative impacts resulting from regional trends related to STR regulations that may result in potentially significant environmental impacts. These trends have potential to increase hotel occupancy rates in Orange County and the Southern California region and driveup room rates, which is particularly concerning with the upcoming 2028 Olympics. Thus, the Proposed Ordinance is a new project with new, potentially significant environmental impacts, that constitutes a substantial change from the conditions contemplated in the GP PEIR and must be subject to new environmental review under CEQA. This letter details a number of fair arguments that the STR ban may cause significant environmental impacts, requiring a new EIR. Moreover, the environmental document prepared for the General Plan was a program EIR. "When a program EIR is employed, if a later proposal is not either the same as or within the scope of the project described in the program EIR ... it is treated as a new project and must be fully analyzed." (Save Our Access v. City of San Diego (2023) 92 Cal.App.5th 819, 845.) [internal quotations and citations omitted].) A program EIR that does not include any discussion or analysis of a later proposed activity is not adequate to inform the public of the environmental effects of that later activity such that the later activity is outside the scope of the program EIR. (Id. at 852-53.) The GP PEIR does not discuss, analyze, or inform the public of the environmental effects associated with the Proposed Ordinance. Therefore, even if the City were to assess the Proposed Ordinance under the GP PEIR, it is not within the scope of the GP PEIR and must be fully analyzed as a new project under CEQA. (Id. at 845 ["The Supreme Court explained `when a program EIR is employed, if a later proposal is not either the same as or within the scope of the project ... described in the program EIR,' then review of the proposal is not governed by section 21166's deferential substantial evidence standard."]) In addition, even if the GP PEIR were relied upon, the high-level, programmatic nature of the GP PEIR translates to a lack of detail that requires much more than a 51-page addendum to correct. Rather, a supplemental or subsequent EIR would be needed because the STR ban cannot be addressed with "minor" changes to the GP PEIR. Under CEQA Guidelines Section 15164, an addendum is only permitted where minor changes are needed to the prior analysis. As detailed herein, the complete absence of prior analysis of STRs, let alone the STR ban, requires changes to many topic areas covered by CEQA and raises new potentially significant impacts that cannot be addressed with minor clarifications. 11