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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 significance of these concerns, the City should prepare a Water Supply Assessment prior to moving forward with an STR ban.54 Operation of Existing Hotels — Solid Waste Regarding solid waste, local, regional, state, and federal statutes and regulations require that the volume of solid waste generation and disposal be reduced overtime, including through use of solid waste reduction programs such as recycling and composting. According to the 2018 Cleantech analysis, Airbnb guests in North America achieved a waste reduction of 64,000 tons.55 An STR ban would increase hotel accommodation solid waste volumes and significantly and cumulatively impact the achievement of solid waste reduction goals and compliance with local and state solid waste statutes and regulations. The City must conduct a study of solid waste generation rates in STRs compared to hotels and calculate the reasonably foreseeable solid waste volume increases that would result from a ban on STRs. Given the sensitivity of California state and local policymakers to solid waste reduction programs, an expert study should be prepared by a qualified waste management expert to support this analysis. Operation of New Hotels All potential impacts to utilities and services systems discussed above regarding operation of existing hotels apply to the operation of potential new hotels. In addition, operation of new hotels will also result in a demand for landscaping, cleaning, and maintenance services. These impacts may be significant in areas of the City where STRs are more prevalent and hotel options are limited or nonexistent. Construction of new hotels would also increase demand for utility services generally. The City's analysis of impacts to utilities in an EIR should also calculate the demand for utilities from the new hotel facilities and determine whether the applicable facilities can accommodate the increase in demand. If existing facilities cannot accommodate the increased utility demand resulting from an STR ban and subsequent addition of new hotel facilities, new or expanded facilities could be required to accommodate this demand (e.g., for water and electricity), the construction of which could be a significant environmental impact. Mitigation measures may need to be provided to reduce impacts to less than significant. Absent any feasible mitigation, impacts to utilities and service systems could be significant. 54 The California Water Code (§10910 et. seq.), based on Senate Bill 610 of 2001 (SB 610), requires a project proponent to assess the reliability of a project's water supply as part of the CEQA process. 55 Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide. 35