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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 Public Services Overview There are a number of potentially significant impacts with respect to public services that could result from an STR ban and require further analysis by the City. Increased utilization of existing hotels as a result of eliminating all STRs in the City is reasonably likely to lead to increased demand for public services, which may be significant. Further, as mentioned above, it is reasonably foreseeable that additional hotels would need to be constructed to accommodate patrons who would have previously utilized STRs. The operation of new hotels has the potential to result in significant environmental impacts with respect to public services. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in public services impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 44.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of impacts to public services from the STR ban is insufficient, finding that the STR ban would only affect existing structures, and that the STR ban would not "introduce new residential units to the city" and that the "residential units illegally operating as STRs were adequately analyzed in the GP PEIR" as part of the GP buildout. (Staff Report, Exhibit 3, p. 44.) The analysis in the Addendum lacks any consideration of the reasonably foreseeable impacts to public services resulting from operation of existing and new hotels. Operation of Existing Hotels As discussed above in the Noise and vibration section, the City failed to evaluate how the potential for noise and nuisance complaints associated with hotels may be greater than those associated with STRs. The City must evaluate the potential for increased demand for public services due to those complaints, which may be significant. Operation of New Hotels With respect to impacts to fire and police facilities, STR restrictions that could result in the construction of new replacement hotels or other facilities would result in increased demand for fire and police protection facilities to maintain acceptable service ratios, response times, or other performance objectives. The City should provide a calculation of the number of calls to police complaining about hotels compared to the number of calls to police regarding STRs, to analyze whether eliminating all STRs and increasing hotel use would increase demand for police services. Mitigation measures may need to be provided to reduce impacts to less than significant. Absent any feasible mitigation, impacts to public services (specifically fire and police) could be significant. 30