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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 />Transportation <br />Overview <br />As discussed in the air quality, energy, and GHG emissions sections above, it is reasonably foreseeable <br />that an STR ban will increase total and peak period transportation demand, trip counts, and VMT in several <br />ways, including (1) by displacing existing STR guests to STRs and hotels located farther away from travel <br />destinations; and (2) stimulating STR replacement accommodation construction and expansion that will <br />increase construction period and operational period material, service supplier, maintenance and traveler <br />vehicle trips and VMT. The Addendum fails to address any of these potential impacts, concluding without <br />supporting evidence that the Proposed Ordinance would "only affect existing structures," would not conflict <br />with regional or local circulation system planning, and that the operational traffic associated with long-term <br />rentals or permanent residences (which the Addendum assumes all STRs would be converted to) was <br />already evaluated in the GP PEIR. Therefore, the Addendum concludes there would be no change to <br />transportation impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 46.) This is <br />inadequate. <br />The impacts described above would significantly conflict with plans, ordinances and polices addressing <br />circulation systems, including transportation system congestion reduction, energy conservation, and <br />criteria and GHG emission reduction goals. Additional VMT generation will significantly conflict with CEQA <br />guidelines Section 15064.3(b), which requires that a CEQA analysis consider and reduce VMT. These <br />impacts would require the imposition of all feasible mitigation under CEQA. The City failed to conduct any <br />analysis of these potential impacts. <br />The Analysis in the Addendum Fails to Address Potentially Significant Impacts <br />The Addendum's analysis of transportation impacts from the STR ban is insufficient, finding that the STR <br />ban would only affect existing structures, and that the STR ban would not conflict with regional or local <br />circulation system planning, and that the operational traffic associated with long-term rentals or permanent <br />residences (which the Addendum assumes all STRs would be converted to) was already evaluated in the <br />GP PEIR. (Staff Report, Exhibit 3, p. 46.) The analysis in the Addendum lacks any consideration of the <br />reasonably foreseeable transportation impacts from increased VMT related to existing and new hotels <br />which will result from eliminating all STRs in the City. <br />Increased VMT— Existing Hotels <br />It is likely that restricting the use of STRs would require patrons to stay at a location (hotel or other facility) <br />that is further from their intended destination, resulting in increased VMT. Guests staying in STRs have <br />more flexibility to stay closer to their destinations, by eliminating STRs in the City, these travelers will need <br />to travel further to reach their destinations. This increase in VMT will additionally lead to an increase in <br />other potentially significant environmental impacts, including GHG emissions and air quality, as discussed <br />above. <br />The ITE Trip Generation Manual, 11 th edition, does not provide average trip rates specifically for STRs. <br />The land use category in the ITE Trip Generation Manual that most closely matches at STR is Land Use <br />31 <br />
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