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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 />• Energy Sources: emissions associated with electricity and natural gas use for space heating and <br />cooling, water heating, energy consumption, and lighting. <br />• Mobile Sources: emissions associated with associated vehicle travel. It is possible new hotels <br />would be constructed farther from a city center or tourist destination, resulting in greater urban <br />sprawl and VMT. <br />• Water/Wastewater: emissions associated with energy used to pump, convey, deliver, and treat <br />water. <br />The GHG Mitigation Measure from the GP PEIR is Inadequate <br />The City cannot rely on the GHG mitigation measure from the GP PEIR to address these potentially <br />significant impacts because, as discussed above, the Proposed Ordinance is a separate project and <br />cannot be addressed through an Addendum to the GP PEIR and, therefore, the mitigation measure from <br />the GP PEIR cannot be applied to this new project. Moreover, the GHG mitigation measure from the GP <br />PEIR would not provide adequate mitigation for the impacts described above, such as increased vMT from <br />elimination of STRs, since the GHG mitigation measure merely requires tracking and monitoring GHG <br />emissions for the Climate Action Plan, which do not help to reduce project specific GHG emissions. (See <br />Staff Report, Exhibit 3, p. 32.) <br />The City is Shirking its Duty to Meet State Climate Goals <br />The City should not discount the importance of evaluating potential GHG impacts from its actions. <br />Curtailing GHG emissions to reduce future climate impacts is one of the highest priority objectives of state <br />and local policymakers and agencies. California has legislatively determined that GHG emissions of any <br />kind contribute to a global climate crisis. The State Is 2022 Scoping Plan includes various recommendations <br />that local governments can implement to align their planning and development review processes with the <br />state's climate goals. Because an STR ban promotes new land use for development of hotels, this <br />promotes a growth in permanent emissions sources, which are less efficient than existing STRs. The City <br />must analyze whether an STR ban would conflict with the 2022 Scoping Plan. <br />At the local level, the Conservation Element of the City 's General Plan provides that the City should <br />"[p]rotect air resources, improve regional and local air quality, and minimize the impacts of climate <br />change." 36 An STR ban may also conflict with General Plan policies to reduce GHG emissions in the City <br />such as "coordinate[ing] air quality planning with local and regional agencies to meet or exceed State or <br />Federal ambient air quality standards" and achieving "[c]onsistency with emission reduction goals <br />highlighted in the Climate Action Plan ... in all major decisions on land use and investments in public <br />infrastructure.1137 The City must analyze whether an STR ban is inconsistent with its General Plan policies. <br />In addition, a project must demonstrate compliance with applicable GHG reduction plans. Therefore, the <br />City's analysis should address consistency of hotel replacement facilities with relevant GHG plans and <br />36 Santa Ana General Plan, Conservation Element, CN-05. <br />37 Ibid. <br />23 <br />
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