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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 Construction and Operation of New Hotels The construction and operation of new hotels has the potential to result in significant environmental impacts with respect to energy. The City must also evaluate whether there is adequate infrastructure to handle the peak load from new hotels. To do so, it must request an assessment from its utility as to infrastructure needed to support these new hotels. It must also examine whether the new hotels require upgrades to utility infrastructure, requiring additional offsite construction activities, and whether the new hotels put residents and businesses at risk for localized failures due to local infrastructure limitations. In addition, the City's General Plan includes various goals and policies to promote energy conservation, including promoting "energy -efficient development patterns by clustering mixed use developments and compatible uses adjacent to public transportation." An STR ban may conflict with these goals and policies by encouraging development of hotels, which are less energy -efficient compared to STRs.32 Greenhouse Gas Emissions Overview All issues associated with the City's failure to adequately analyze air quality and energy impacts in the Addendum carry over to the City's failure to calculate GHG emissions. As discussed in the technical environmental report prepared by Ramboll, the STR ban would result in an increase of daily mobile emissions of GHG by 443 percent, contributing to a significant increase in emissions in the area in direct conflict with regional and state goals to reduce vMT and GHG emissions from vehicle trips. (Ramboll Environmental Analysis, p. 4.) Further, Ramboll concluded that the increased energy demand associated with hotels compared to STRs would result in a 179 percent increase in GHG emissions per person. (Ramboll Environmental Analysis p. 8.) The Addendum fails to address any of the potential GHG emissions impacts, concluding without supporting evidence that the STR ban would not result in a substantial increase in GHG emissions from new construction or increased occupancy levels compared to the GP EIRGP PEIR. (Staff Report, Exhibit 3, p. 33.) This is unsupported by the evidence in the record and inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of GHG emissions impacts is insufficient, finding that the STR ban would "only affect existing structures," that "GHG emissions due to construction activities would not occur," and that the STR ban is "not anticipated to result in a substantial increase in GHG emissions, either directly or indirectly." (Staff Report, Exhibit 3, p. 33.) The Addendum also concludes that the STR ban "would not result in any increase in occupancy levels analyzed in the GP PEIR and does not involve construction of any new units that might lead to an increase in GHG emissions." (Ibid.) This analysis is entirely superficial, lacking any consideration of the reasonably foreseeable impacts of an STR ban, including increased vMT, 32 General Plan, Conservation Element, CN-10. 21