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I to make up for the loss in overnight accommodations STRs currently provide, and urban decay if <br /> 2 the ban ultimately results in homeowners being unable to afford their homes and causing <br /> 3 businesses to shutter from the decline in tourism and transitory resident revenue. <br /> 4 51. On April 16, 2024, the City Council ultimately approved the STR Ban "on <br /> 5 consent," meaning it engaged in no deliberation on the topic. In doing so, the City Council <br /> 6 concluded that the STR Ban was not a"project"under CEQA. The City did not address the letters <br /> 7 arguing otherwise. And having concluded the STR Ban was not a "project," the City failed to <br /> 8 conduct any environmental review. <br /> 9 Ordinance No. NS-3061 Did Not Exempt Existing Lawful STRs from the Ban <br /> 10 52. The STR Ban completely prohibits STRs throughout the City and did not provide <br /> 11 any grandfathering, amortization, or just compensation for existing, lawfully operating STRs. As <br /> 12 explained above, the City took this action despite correspondence provided to the City Council <br /> 13 informing it that the blanket ban on STRs in the City would have a drastic economic impact on <br /> 14 STR owners. Rental Alliance members will face these drastic impacts. The City has placed STR <br /> 15 owners and operators in an untenable economic position. Not only will the properties face <br /> 16 decreasing value, owners could also be forced to sell their homes due to the immediate loss of STR <br /> 17 income and the inability to maintain mortgages, and operators will immediately lose their <br /> 18 established business and livelihood. <br /> 19 <br /> 20 FIRST CLAIM FOR RELIEF <br /> 21 (Writ of Mandate Due to Failure to Comply with CEQA— Code of Civil Procedure <br /> §§ 1085, 1094.5 and Public Resources Code §§ 21000 et seq.) <br /> 22 53. Petitioner incorporates by reference all preceding paragraphs as though set forth <br /> 23 fully herein. <br /> 24 54. An actual and justiciable controversy has arisen and now exists between Petitioner <br /> 25 and the City,concerning whether the City's environmental determination complies with California <br /> 26 <br /> 27 <br /> 28 <br /> VERTFTED PETTTTON FOR WRTT OF MANDATE <br /> 15 AND COMPLATNT <br />