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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 hotels, and development of new hotels to make up for the loss of overnight accommodations. The City must evaluate these potential cumulative impacts. Impact Analysis The below describes and evaluates several potentially significant adverse environmental impacts that will or are reasonably likely to occur as a result of a ban of STRs in the City. This analysis is supplemented by technical reports prepared by Ramboll which provide further analysis related to air quality, energy, greenhouse gas, land use and planning, noise and vibration, and transportation impacts. The Addendum fails to account for any of these potential impacts, entirely ignoring the foreseeable impacts resulting from elimination of all STRs in the City discussed above. This is a fatal flaw, and the City must prepare an Environmental Impact Report to evaluate the STR ban. Project Description The description of the STR ban in the Addendum does not meet CEQA's requirements for an adequate project description. Under CEQA, "[a]n accurate and complete project description is necessary for an intelligent evaluation of the potential environmental impacts of the agency's action. (City of Redlands v. County of San Bernardino (2002) 96 Cal.App.4t" 398, 405.) "If the description is inadequate because it fails to discuss the complete project, the environmental analysis will probably reflect the same mistake." (Dry Creek Citizens Coalition v. County of Tulare (1999) 70 Cal .App.4t" 20, 31, 32. ) The Addendum describes the "project' as an ordinance "to expressly prohibit short-term rentals within the city", claiming that the existing Municipal Code "does not and has never listed short-term rentals as a permissible use in any zoning district. As such STRs are prohibited and unauthorized..." (Staff Report, Attachment 3, p. 13.) The City fails to accurately describe the project. As discussed in greater detail in the legal analysis submitted by the Santa Ana Short -Term Rental Alliance, the City's position that STRs are illegal and have never been permitted in the City is incorrect. STRs are existing, lawful residential uses of property that have been operating in the City for decades. The ordinance, therefore, is not reaffirming existing law, but imposing a new prohibition on short-term rentals and eliminating all existing, legal short-term rentals. Mitigation Measures As discussed above, reliance on an Addendum to the GP PEIR is inappropriate because the Proposed Ordinance is a different project from the City's General Plan and environmental analysis of the Proposed Ordinance thus cannot be accomplished through an addendum. It follows that the City would be unable to rely on the mitigation measures from the GP PEIR to mitigate the potentially significant environmental impacts described herein to less than significant. Instead, the City must prepare an EIR for the Proposed Ordinance with mitigation measures designed to address any significant impacts. 11