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CAJA Environmental Services, LLG 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of energy impacts is insufficient, finding that that the STR ban would not result in any "construction -related energy consumption" or "any physical impacts to the environment" and that there would be no new or more severe significant energy impacts beyond any identified in the GP PEIR. (Staff Report, Exhibit 3, p. 28.) This analysis is entirely superficial, lacking any consideration of the reasonably foreseeable impacts of an STR ban, including increased energy use from hotels within and outside of the City, and construction and operation of new hotels. Energy impacts are a significant concern for local and state policymakers and agencies. For example, the Conservation Element of the City's General Plan provides that the City should "[p]rotect air resources, improve regional and local air quality, and minimize the impacts of climate change.9929 Reducing energy use is critical to helping improve air resources and minimize the impacts of climate change. The analysis of energy use relative to applicable health, safety, and emission regulations is highly technical and relies on specialized models. The City's further analysis of energy impacts from an STR ban should be supported with a technical study prepared by a qualified expert with significant energy impact model experience. Increased Energy Use from Hotels in City and Outside City Ramboll concluded the STR ban would increase energy demands because hotels use more energy per person than STRs, using more than five times more electricity per person and more than two times more natural gas per person. (Ramboll Environmental Analysis, pp. 7-8.) This is consistent with the 2018 Cleantech analysis conclusion that significantly less energy is used when guests stay in an STR compared to a hote1.30 Further, an article published in the Small Business Institute Journal proposed that sharing economy -based accommodations are likely to consume less energy than traditional accommodations because the sharing economy takes advantage of "slack" resources which already exist, rather than creating new facilities.31 In other words, STRs use structures that already exist to provide overnight accommodations and help to alleviate demand for new hotels. By increasing VMT, the STR ban would also increase reliance on fossil fuels to power vehicle trips — the daily mobile fuel consumption for hotels is more than five times greater for hotels compared to STRs for both gasoline and diesel. (Ramboll Environmental Analysis, p. 8.) By eliminating all STRs from the City, an STR ban will cause visitors to stay in existing hotels in the City, increase the electrical demand from existing hotels, increase fossil fuel consumption from vehicles, and foreseeably result in significant impacts due to wasteful, inefficient, and unnecessary consumption of energy resources. This directly conflicts with state and local renewable energy and energy efficiency plans. These impacts may be significant and cumulatively substantial and require the imposition of all feasible mitigation. If feasible mitigation is not available, impacts could be significant. The City must analyze these potential impacts. 29 General Plan, Conservation Element, CN-05. 3o Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide. 31 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, pp. 60- 61 (2017). 20