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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 />household supplies. As discussed above, STRs compete with hotels by offering a different sort of service <br />with a unique structure, and STRs "pop up throughout cities where there is demand for lodging. They do <br />not require centralization... Rentals offer a more sustainable option that requires fewer resources and <br />helps increase access with more diverse accommodation options and better value.9145 Further, STRs "are <br />critical to regional economies, offering unique and affordable experiences to visitors, generating significant <br />tax revenue to support local governments, and providing hosts significant income.9946 <br />An STR ban could have devastating effects on local businesses, including restaurants and small <br />businesses, that are not in the areas where hotels exist or would be developed. As set forth in the Economic <br />Prosperity Element of the City's General Plan, the City has established goals of attracting businesses to <br />"strengthen and expand citywide business attraction efforts in order to achieve the city's full employment <br />potential," and "stimulate the local economy through tourism."47 The City did not analyze any of the potential <br />impacts of an STR ban to this sector of the economy and how this could contribute to urban decay and <br />conflict with the City's General Plan. Potential for lost revenue from tourism is discussed in greater detail <br />in the economic analysis prepared by Ramboll. The City must evaluate this evidence in an EIR. <br />Noise and Vibration <br />Overview <br />Ramboll concluded that there are a number of potentially significant noise impacts that could result from <br />an STR ban and require further analysis by the City. Increased use of existing hotels due to loss of all <br />STRs in the City is reasonably likely to lead to increased operational and traffic noise impacts, which may <br />be significant. Further, it is reasonably foreseeable that additional hotels or other similar facilities would <br />need to be constructed to accommodate patrons who would have previously utilized STRs, and this <br />construction has the potential to result in significant noise and vibration impacts. The Addendum fails to <br />address any of these potential impacts, concluding without supporting evidence that the Proposed <br />Ordinance would "only affect existing structures" and therefore, there would be no change in noise impacts <br />beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 41.) The Addendum does not even <br />discuss potential vibration impacts in its evaluation of the STR ban. (See Id., p. 41.) This is inadequate. <br />The Analysis in the Addendum Fails to Address Potentially Significant Impacts <br />The Addendum's analysis of noise impacts is insufficient, finding that the STR ban would only affect <br />existing structures, "[n]o impacts related to construction -related noise level increases would occur," and <br />no increases in transportation noise are anticipated. (Staff Report, Exhibit 3, p. 41.) The Addendum does <br />not even address potential vibration impacts from construction of new hotels. The analysis in the <br />Addendum lacks any consideration of the reasonably foreseeable noise impacts resulting from <br />construction and operation of new hotels. <br />45 King and Jenkins, Unequal Access: Protecting Affordable Accommodations Along the California Coast (2020). <br />46 Dubetz et al, Staying Power.- The Effects on Short -Term Rentals on California's Tourism Economy and Housing <br />Affordability, Milken Institute, p. 1 (2022). <br />47 Santa Ana General Plan, Economic Prosperity Element, EP 04. <br />27 <br />