Laserfiche WebLink
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 />Air Quality <br />Overview <br />As discussed in greater detail in the technical environmental report from Ramboll, an STR ban is <br />reasonably likely to significantly impact air quality in several ways, including adverse impacts due to <br />increased VMT of visitors traveling longer distances to reach travel destinations, and from the reasonably <br />foreseeable construction and operation of new hotels to accommodate patrons who would have previously <br />utilized STRs. The Addendum fails to address any of these potential impacts, concluding without <br />supporting evidence that the Proposed Ordinance "would not result in any physical impacts on the <br />environment or impacts associated with air quality," and that there would be no change in air quality <br />impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 21.) This is inadequate. <br />The Analysis in the Addendum Fails to Address Potentially Significant Impacts <br />The Addendum's analysis of air quality impacts is insufficient, finding that that increases in air quality <br />impacts "are based on construction of new structures generating new vehicle trips or population growth." <br />Since the Proposed Ordinance "would only affect existing structures [and] would not induce population <br />growth," there would be no change in air quality impacts beyond those identified in the GP PEIR, and <br />therefore no impacts would occur with respect to air quality. (Staff Report, Exhibit 3, p. 21.) This analysis <br />is entirely superficial, lacking any consideration of the reasonably foreseeable impacts of an STR ban <br />including increased VMT, increased criteria air emissions from hotels within and outside of the City, and <br />construction of new hotels. <br />Air quality impacts are a significant concern for local and state policymakers and agencies. The <br />Conservation Element of the City's General Plan provides that the City should "[p]rotect air resources, <br />improve regional and local air quality, and minimize the impacts of climate change."19 Further, as detailed <br />in the technical environmental report from Ramboll, the STR ban will disproportionately burden <br />environmental justice communities given the City's existing pollution burdens from regional pollution and <br />localized traffic exposure near existing hotel stock, and the potential for increased hotel usage in response <br />to the STR ban. <br />Increased VMT <br />An STR ban is likely to displace a substantial number of existing travelers from overnight accommodations <br />located in closer proximity to travel destinations and residents staying in temporary overnight <br />accommodations located in closer proximity to schools and places of employment. Many families who seek <br />overnight accommodations prefer to stay in STRs for a variety of reasons, since STRs can meet more <br />specialized accommodation needs compared to hotels. Visitors and residents who choose to stay in STRs <br />in other, less regulated areas of Southern California will then have to drive greater distances, consume <br />more energy, and increase criteria air emissions. <br />19 Santa Ana General Plan, Conservation Element, CN-05. <br />12 <br />