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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 />Operation of Existing Hotels <br />The elimination of all STRs in the City is reasonably likely to cause increased demand for existing hotel <br />accommodations in the City. Ramboll concluded the STIR ban could concentrate traffic on roadways going <br />to hotels in the area, since more than half of the hotels in the City are located in one concentrated area of <br />the City, resulting in noise impacts above the City's General Plan Noise Element standard of 65 dBA CNEL, <br />potentially exacerbating existing noise impacts or creating a new noise impact. (Ramboll Environmental <br />Analysis, pp. 9-10.) <br />The City failed to evaluate how the potential noise and nuisance complaints associated with hotels may <br />be greater than those associated with STRs. To understand the potential impacts from increased use of <br />existing hotels, the City should calculate the total noise complaints associated with STRs it has received, <br />and the total noise complaints associated with hotels, to understand if there is any appreciable difference <br />between the noise complaints received from these accommodations. The City also failed to analyze how <br />this increased demand could lead to potentially significant operational noise impacts from visitors using <br />the facilities, including outdoors areas of hotels such as pools and recreation areas. The City must analyze <br />these potential impacts from the increased use of existing hotels. <br />In addition, it is likely that restricting the use of STRs would require patrons to stay at a hotel or other facility <br />that is further from their intended destination, again resulting in increased vMT, and potentially higher <br />noise levels from increased traffic. As discussed in the technical environmental analysis prepared by <br />Ramboll, shifting traffic to residential or other noise -sensitive areas within the City that are currently below <br />the City's noise threshold could result in a significant impact. The City must evaluate this potential impact. <br />Construction of New Hotels <br />Ramboll estimates the STIR ban will potentially cause significant noise impacts related to hotel <br />construction, exceeding the City's General Plan Noise Element standard and the City's noise ordinance. <br />(Ramboll Environmental Analysis, pp. 11-12.) Construction equipment including heavy machinery can <br />result in significant noise impacts, with sound levels ranging from approximately 75 to 90 dBA (typical <br />suburban/urban background sound levels are commonly on the order of 45 to 55 dBA during daytime hours <br />and lower during nighttime hours) assuming typical receptor distances of 500 ft to 50 ft, and construction <br />may sometimes need to occur at night due to various limitations or time constraints, which may be <br />particularly prevalent over the next few years as hotel construction in Southern California increases to <br />meet hotel demand for the 2028 Olympics. (Ramboll Environmental Analysis, p. 13.) Because sound <br />pressure levels from construction of new hotels, which will be needed due to the STIR ban, have the <br />potential to cause a temporary increase above the noise level threshold, the City must conduct further <br />analysis to evaluate potentially significant impacts and any necessary mitigation. (Ramboll Environmental <br />Analysis, pp. 13-14.) <br />The City should prepare an analysis to quantify projected noise levels from construction of the new hotels <br />in the designated areas identified in the General Plan, Specific Plans, and Zoning Code for hotel <br />development. This analysis should be based on specific parameters for the proposed new uses being <br />28 <br />
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