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CAJA Environmental Services, LLG
<br />9410 Topanga Canyon Blvd., Suite 101
<br />Chatsworth, CA 91311
<br />Phone 310-469-6700 Fax 310-806-9801
<br />diverse needs.40 Policy LU-4.3 "encourage[s] land uses and strategies that reduce energy and water
<br />consumption, waste and noise generation, soil contamination, air quality impact, and light pollution.9941 As
<br />discussed above, a 2018 Cleantech analysis found that when guests stay at an STIR, significantly less
<br />energy and water is used, greenhouse gas emissions are lower, and waste is reduced, compared to hotel
<br />stays42 and an article published in the Small Business Institute Journal also proposed that sharing economy
<br />based accommodations are likely to consume less energy and water, and produce fewer GHG emissions
<br />and less waste, than traditional accommodations.43 By removing the ability of hosts to operate STRs from
<br />existing residences, the City is acting in a manner inconsistent with its Land Use Element policy to
<br />encourage resources efficient land uses. The City is inappropriately relying entirely on the Land Use
<br />Element goal of preserving the character of residential neighborhoods, without any substantial evidence
<br />to demonstrate that STRs in the City are having a negative impact on the character of residential
<br />neighborhoods and ignoring the other goals and policies of the Land Use Element.
<br />Construction of New Hotels
<br />It is reasonably foreseeable that an STIR ban will disperse existing STIR users to other locations that permit
<br />STRs and induce hotel development. These changes from existing conditions could foreseeably conflict
<br />with the City's General Plan plans, policies, and regulations, requiring analysis under CEQA as to whether
<br />there would be a significant environmental impact due to a conflict with a land use plan, policy, or regulation
<br />adopted for the purpose of avoiding or mitigating an environmental effect.
<br />The City's General Plan Land Use Element, Policy LU-4.5 aims to "[c]oncentrate development along high
<br />quality transit corridors to reduce vehicle miles traveled (VMT) and transportation -related carbon
<br />emissions.9944 As discussed above, the City has identified in its General Plan, Specific Plans, and Zoning
<br />Code certain locations for hotel development. Many of these locations identified for potential development
<br />of new hotels may not be centrally located to promote sustainable development, an STIR ban may be
<br />inconsistent with the City's General Plan.
<br />Urban Decay
<br />An STIR ban also has potential to result in urban decay, which the City must analyze. Loss of business
<br />revenue from tourists unable to secure alternative lodging and unwilling to travel from neighboring areas
<br />to the City could cause distressing effects in the business community, potentially leading to business
<br />closures and urban decay.
<br />The STIR market contributes to the local economy by employing many people, including those working
<br />pool service, drycleaning, upholstery, catering, bike rentals, yoga studios, transportation, restaurants,
<br />wineries, tasting rooms, groceries, home repair and improvement, nurseries and landscaping, and
<br />40 General Plan, Land Use Element, LU-5.
<br />41 Ibid.
<br />42 Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018),
<br />https://news.airbnb.com/how-the-airbnb-community-supports-environmental) -friendly-travel-worldwide.
<br />43 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, pp. 61-
<br />63 (2017).
<br />44 Santa Ana General Plan, Land Use Element, LU-08.
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