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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 hauling, etc.). The results should then be compared to the applicable regional and localized significance thresholds to determine whether the construction activities would have the potential to result in exceedances of applicable daily thresholds that could subsequently cause cumulatively considerable increases in emissions of pollutants for which the region is designated as non -attainment. If regional or localized construction emissions exceed the applicable daily thresholds for any criteria pollutants, mitigation measures, if feasible, would need to be provided to reduce impacts to less than significant. If feasible mitigation is not available, impacts could be significant. As described above, the City's General Plan, various Specific Plans, and Zoning Code have identified certain locations in the City appropriate for hotels. Depending on the availability of land to construct these new hotels in these identified areas, it is possible that they would be constructed farther from a city center or tourist destinations, resulting in greater urban sprawl and vehicle miles traveled (VIVIT). The City failed to analyze whether the reasonably foreseeable construction of new hotels as a result of an STR ban may be inconsistent with growth projections in the applicable regional air quality plan or result in emissions that exceed thresholds. The City also failed to study whether construction of new hotels in the areas identified in the General Plan may have adverse impacts on environmental justice areas, where pursuant to Policy CN-1.5 of the Conservation Element of the General Plan, the City should "[s]tudy the impacts of stationary and non -stationary emission sources on existing and proposed sensitive uses and opportunities to minimize health and safety risks" and "[d]evelop and adopt new regulations avoiding the siting of facilities that potentially emit increased pollution near sensitive receptors within environmental justice area boundaries.3321 The City must conduct this analysis in an EIR to understand all potential air quality impacts of an STR ban. Air Quality Mitigation Measures from the GP PEIR are Inadequate The City cannot rely on the air quality mitigation measures from the GP PEIR to address these potentially significant air quality impacts because, as discussed above, the Proposed Ordinance is a separate project and cannot be addressed through an Addendum to the GP PEIR and, therefore, the mitigation measures from the GP PEIR cannot be applied to this new project. Moreover, the air quality mitigation measures from the GP PEIR would not provide adequate mitigation for the impacts described above, such as increased VMT from elimination of STRs, since the air quality mitigation measures are primarily aimed at construction impacts and site -specific developments. (See Staff Report, Exhibit 3, pp. 18-19.) Biological Resources Overview An STR ban may significantly impact biological resources from the reasonably foreseeable construction of new hotels to accommodate patrons who would have previously utilized STRs. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in biological 21 Santa Ana General Plan, Conservation Element, CN-05. 15