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Correspondence - PH #35
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Correspondence - PH #35
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City Clerk
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35
Date
11/19/2024
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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 />Construction and Operation of New Hotels <br />The construction and operation of new hotels has the potential to result in significant environmental impacts <br />with respect to energy. The City must also evaluate whether there is adequate infrastructure to handle the <br />peak load from new hotels. To do so, it must request an assessment from its utility as to infrastructure <br />needed to support these new hotels. It must also examine whether the new hotels require upgrades to <br />utility infrastructure, requiring additional offsite construction activities, and whether the new hotels put <br />residents and businesses at risk for localized failures due to local infrastructure limitations. <br />In addition, the City's General Plan includes various goals and policies to promote energy conservation, <br />including promoting "energy -efficient development patterns by clustering mixed use developments and <br />compatible uses adjacent to public transportation." An STR ban may conflict with these goals and policies <br />by encouraging development of hotels, which are less energy -efficient compared to STRs.32 <br />Greenhouse Gas Emissions <br />Overview <br />All issues associated with the City's failure to adequately analyze air quality and energy impacts in the <br />Addendum carry over to the City's failure to calculate GHG emissions. As discussed in the technical <br />environmental report prepared by Ramboll, the STR ban would result in an increase of daily mobile <br />emissions of GHG by 443 percent, contributing to a significant increase in emissions in the area in direct <br />conflict with regional and state goals to reduce vMT and GHG emissions from vehicle trips. (Ramboll <br />Environmental Analysis, p. 4.) Further, Ramboll concluded that the increased energy demand associated <br />with hotels compared to STRs would result in a 179 percent increase in GHG emissions per person. <br />(Ramboll Environmental Analysis p. 8.) The Addendum fails to address any of the potential GHG emissions <br />impacts, concluding without supporting evidence that the STR ban would not result in a substantial <br />increase in GHG emissions from new construction or increased occupancy levels compared to the GP <br />EIRGP PEIR. (Staff Report, Exhibit 3, p. 33.) This is unsupported by the evidence in the record and <br />inadequate. <br />The Analysis in the Addendum Fails to Address Potentially Significant Impacts <br />The Addendum's analysis of GHG emissions impacts is insufficient, finding that the STR ban would "only <br />affect existing structures," that "GHG emissions due to construction activities would not occur," and that <br />the STR ban is "not anticipated to result in a substantial increase in GHG emissions, either directly or <br />indirectly." (Staff Report, Exhibit 3, p. 33.) The Addendum also concludes that the STR ban "would not <br />result in any increase in occupancy levels analyzed in the GP PEIR and does not involve construction of <br />any new units that might lead to an increase in GHG emissions." (Ibid.) This analysis is entirely superficial, <br />lacking any consideration of the reasonably foreseeable impacts of an STR ban, including increased vMT, <br />32 General Plan, Conservation Element, CN-10. <br />21 <br />
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