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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 increased GHG emissions from the construction and operation of new hotels, and construction and operation of new hotels. Increased VMT Eliminating all STRs in the City will foreseeably increase GHG emissions by displacing existing STIR guests to less regulated areas farther from their travel destinations, which will increase VMT and GHG emissions. Ramboll concluded that the STIR 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.) Increased Criteria Air Emissions from Hotels in City and Outside City Eliminating all STRs in the City will relocate existing STIR guests to less efficient hotels and other replacement facilities likely to result in greater GHG emissions than STRs. When guests stay at an STIR, significantly less energy is used, and GHG emissions are lower compared to hotel stays.33 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.) This is consistent with the 2018 Cleantech analysis, which found that significantly lower GHG emissions result from a stay in an STIR compared to hotel stays,34 and the Small Business Institute Journal article, which proposed that sharing economy -based accommodations are likely to produce fewer GHG emissions than traditional accommodations because the sharing economy takes advantage of "slack" resources which already exist, rather than creating new facilities that emit additional GHGs.35 As such, GHG emission increases reasonably related to the imposition of an STIR ban will result in significant impacts to the environment and adversely affect the achievement of plans and policies adopted by state and local governments to reduce GHG emissions. Construction and Operation of New Hotels Eliminating all STRs in the City will foreseeably increase GHG emissions by stimulating replacement accommodation construction and expansion that will increase GHG emissions related to new material manufacturing, transportation and installation, heavy equipment use, and maintenance, as well as operation of these new hotels further contributing to GHG emissions increases that Ramboll projected from increased reliance on hotels. Specifically, the construction and operation of new hotels would result in the increased GHG emissions from a number of sources, including: • Construction: emissions associated with construction -related equipment and vehicle use. • Area Sources: emissions associated with the on -site use of powered equipment. 33 Airbnb, Airbnb: Helping travel grow greener, p. 3 (Mar. 2017); Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 2017 SMALL BUSINESS INST. J. 13.2, pp. 61-63. 34 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 35 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, p. 61 (2017). 22