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								    CAJA Environmental Services, LLG 
<br />9410 Topanga Canyon Blvd., Suite 101 
<br />Chatsworth, CA 91311 
<br />Phone 310-469-6700 Fax 310-806-9801 
<br />An STR Ban Will Increase Reliance on More Environmentally Impactful Hotels and Thereby Increase the 
<br />Environmental Impacts of Tourism 
<br />An STR ban will also cause more visitors and residents in need of temporary overnight accommodations 
<br />to rely on hotels for those accommodations. STRs are operated out of existing homes and do not require 
<br />the same intensive use of water, energy, and other environmental resources that hotels require. Ramboll 
<br />concluded that the STR ban will result in increased criteria air pollutant and GHG emissions and associated 
<br />health risks, increased noise impacts, increased traffic congestion, and other potentially significant 
<br />environmental impacts. (See Ramboll Environmental Analysis.) 
<br />Ramboll's City -specific findings are consistent with a variety of recent studies and models concerning the 
<br />environmental and economic benefits of STRs. A 2018 analysis using a "Cleantech" model found that 
<br />when guests stay at an STR, significantly less energy and water is used, GHG emissions are lower, and 
<br />waste is reduced compared to hotel stays.5 The 2018 analysis shows that in 2017, Airbnb guests in Europe 
<br />who stayed at an STR instead of a hotel achieved energy savings equal to that of 826,000 homes and 
<br />reduced water usage equal to 13,000 Olympic -sized swimming pools.6 Airbnb guest stays in North America 
<br />resulted in lower GHG emissions equal to that of over 354,000 cars and waste reduction of 64,000 tons 
<br />compared to hotel stays.? An article published in the Small Business Institute Journal also proposed that 
<br />sharing economy based accommodations are likely to consume less energy and water, and produce fewer 
<br />GHG emissions and less waste, than traditional accommodations.$ Further, the "Trip Generation Model" 
<br />prepared by International Transportation Engineers (ITE),' confirms that a residential home generates less 
<br />traffic than a hotel. In addition, a 2020 report regarding STRs along the California coast found that "The 
<br />sharing economy can compete with hotels by offering a different sort of service with a unique structure. 
<br />STRs pop up throughout cities where there is demand for lodging. They do not require centralization or 
<br />maintaining inventory, which helps lower costs ... Rentals offer a more sustainable option that requires 
<br />fewer resources and helps increase access with more diverse accommodation options and better value.9910 
<br />For all these reasons, the transition of STR guests to hotel guests has the potential to result in increased 
<br />demand for water, electricity, and natural gas, and the increased generation of GHG emissions, 
<br />wastewater and solid waste, and increased traffic. And, as further detailed below, this can result in a wide 
<br />range of potentially significant environmental effects to air quality, energy, GHG emissions, land use and 
<br />planning, noise, public services, transportation, and utilities. 
<br />5 Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), 
<br />https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide. 
<br />6 Ibid. 
<br />7 Ibid. 
<br />8 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, pp. 61- 
<br />63 (2017). 
<br />9 ITE, Trip Generation Manual, 11th Ed. (TripGen11), available for purchase here: https://www.ite.org/technical- 
<br />resou rces/topics/tri p-and-parki ng- 
<br />generation/#:-:text=The%201TE%20Trip%20Generation%20Manual%20presents%20a%20summary%20of%20the 
<br />,to%20the%20Trip%20Generation%20Manual. 
<br />11 King and Jenkins, Unequal Access: Protecting Affordable Accommodations Along the California Coast (2020). 
<br />8 
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