My WebLink
|
Help
|
About
|
Sign Out
Home
Browse
Search
Correspondence - PH #35
Clerk
>
Agenda Packets / Staff Reports
>
City Council (2004 - Present)
>
2024
>
11/19/2024
>
Correspondence - PH #35
Metadata
Thumbnails
Annotations
Entry Properties
Last modified
12/17/2024 5:14:27 PM
Creation date
11/13/2024 2:37:20 PM
Metadata
Fields
Template:
City Clerk
Item #
35
Date
11/19/2024
Jump to thumbnail
< previous set
next set >
There are no annotations on this page.
Document management portal powered by Laserfiche WebLink 9 © 1998-2015
Laserfiche.
All rights reserved.
/
211
PDF
Print
Pages to print
Enter page numbers and/or page ranges separated by commas. For example, 1,3,5-12.
After downloading, print the document using a PDF reader (e.g. Adobe Reader).
View images
View plain text
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 />The Analysis in the Addendum Fails to Address Potentially Significant Impacts <br />The Addendum's analysis of energy impacts is insufficient, finding that that the STR ban would not result <br />in any "construction -related energy consumption" or "any physical impacts to the environment" and that <br />there would be no new or more severe significant energy impacts beyond any identified in the GP PEIR. <br />(Staff Report, Exhibit 3, p. 28.) This analysis is entirely superficial, lacking any consideration of the <br />reasonably foreseeable impacts of an STR ban, including increased energy use from hotels within and <br />outside of the City, and construction and operation of new hotels. <br />Energy impacts are a significant concern for local and state policymakers and agencies. For example, 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.9929 Reducing energy <br />use is critical to helping improve air resources and minimize the impacts of climate change. The analysis <br />of energy use relative to applicable health, safety, and emission regulations is highly technical and relies <br />on specialized models. The City's further analysis of energy impacts from an STR ban should be supported <br />with a technical study prepared by a qualified expert with significant energy impact model experience. <br />Increased Energy Use from Hotels in City and Outside City <br />Ramboll concluded the STR ban would increase energy demands because hotels use more energy per <br />person than STRs, using more than five times more electricity per person and more than two times more <br />natural gas per person. (Ramboll Environmental Analysis, pp. 7-8.) This is consistent with the 2018 <br />Cleantech analysis conclusion that significantly less energy is used when guests stay in an STR compared <br />to a hote1.30 Further, an article published in the Small Business Institute Journal proposed that sharing <br />economy -based accommodations are likely to consume less energy than traditional accommodations <br />because the sharing economy takes advantage of "slack" resources which already exist, rather than <br />creating new facilities.31 In other words, STRs use structures that already exist to provide overnight <br />accommodations and help to alleviate demand for new hotels. By increasing VMT, the STR ban would <br />also increase reliance on fossil fuels to power vehicle trips — the daily mobile fuel consumption for hotels <br />is more than five times greater for hotels compared to STRs for both gasoline and diesel. (Ramboll <br />Environmental Analysis, p. 8.) <br />By eliminating all STRs from the City, an STR ban will cause visitors to stay in existing hotels in the City, <br />increase the electrical demand from existing hotels, increase fossil fuel consumption from vehicles, and <br />foreseeably result in significant impacts due to wasteful, inefficient, and unnecessary consumption of <br />energy resources. This directly conflicts with state and local renewable energy and energy efficiency plans. <br />These impacts may be significant and cumulatively substantial and require the imposition of all feasible <br />mitigation. If feasible mitigation is not available, impacts could be significant. The City must analyze these <br />potential impacts. <br />29 General Plan, Conservation Element, CN-05. <br />3o 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 />31 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, pp. 60- <br />61 (2017). <br />20 <br />
The URL can be used to link to this page
Your browser does not support the video tag.