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iCAJA Environmental Services, LLC 9410 Topanga Canyon Blvd.,Suite 101 Chatsworth,CA 91311 Phone 310-469-6700 Fax 310-806-9801 • Energy Sources: emissions associated with electricity and natural gas use for space heating and cooling, water heating, energy consumption, and lighting. • Mobile Sources: emissions associated with associated vehicle travel. It is possible new hotels would be constructed farther from a city center or tourist destination, resulting in greater urban sprawl and VMT. • Water/Wastewater: emissions associated with energy used to pump, convey, deliver, and treat water. The GHG Mitigation Measure from the GP PEIR is Inadequate The City cannot rely on the GHG mitigation measure from the GP PEIR to address these potentially significant impacts because, as discussed above, the Proposed Ordinance is a separate project and cannot be addressed through an Addendum to the GP PEIR and, therefore, the mitigation measure from the GP PEIR cannot be applied to this new project. Moreover, the GHG mitigation measure from the GP PEI R would not provide adequate mitigation for the impacts described above, such as increased VMT from elimination of STRs, since the GHG mitigation measure merely requires tracking and monitoring GHG emissions for the Climate Action Plan, which do not help to reduce project specific GHG emissions. (See Staff Report, Exhibit 3, p. 32.) The City is Shirking its Duty to Meet State Climate Goals The City should not discount the importance of evaluating potential GHG impacts from its actions. Curtailing GHG emissions to reduce future climate impacts is one of the highest priority objectives of state and local policymakers and agencies. California has legislatively determined that GHG emissions of any kind contribute to a global climate crisis. The State's 2022 Scoping Plan includes various recommendations that local governments can implement to align their planning and development review processes with the state's climate goals. Because an STR ban promotes new land use for development of hotels, this promotes a growth in permanent emissions sources, which are less efficient than existing STRs. The City must analyze whether an STR ban would conflict with the 2022 Scoping Plan. At the local level, the Conservation Element of the City's General Plan provides that the City should "[p]rotect air resources, improve regional and local air quality, and minimize the impacts of climate change.,36 An STR ban may also conflict with General Plan policies to reduce GHG emissions in the City such as "coordinate[ing] air quality planning with local and regional agencies to meet or exceed State or Federal ambient air quality standards" and achieving "[c]onsistency with emission reduction goals highlighted in the Climate Action Plan ... in all major decisions on land use and investments in public infrastructure.,37 The City must analyze whether an STR ban is inconsistent with its General Plan policies. In addition, a project must demonstrate compliance with applicable GHG reduction plans. Therefore, the City's analysis should address consistency of hotel replacement facilities with relevant GHG plans and 36 Santa Ana General Plan, Conservation Element, CN-05. 37 Ibid. 23