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