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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 policies, such as the Climate Change Scoping Plan, SCAG's Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), and any other local plans and/or policies. Reducing GHG emissions is critical to helping improve air resources and minimize the impacts of climate change. Due to the significance of this issue and the complexity of GHG emissions calculations, which require complex technical expertise and knowledge of existing and potential sources, an expert study conducted by recognized climate and emissions specialist using established emission methodologies should be prepared to support the City's GHG emissions impact analysis. The City should also prepare an analysis to quantify the GHG emissions generated from constructing these new facilities. This analysis should be prepared using CalEEMod and based on specific parameters for the proposed new uses being constructed (including size of the new use as well construction schedule, construction equipment, amount of grading, amount of hauling, etc.). Likewise, operational emissions of GHGs should be quantified using CalEEMod. The City has used a screening threshold of 3,000 MTCO2e for GHG emissions. Therefore, the results from CalEEMod should then be compared to this significance threshold to determine whether impacts would be significant. Hazards & Hazardous Materials Overview An STR ban may significantly impact related to hazards and hazardous materials from the reasonably foreseeable construction of new hotels to accommodate patrons who would have previously utilized STRs. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in hazards and hazardous materials impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 35.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of hazards and hazardous materials impacts is insufficient, finding that the STR ban would only affect existing structures, and "is not anticipated to result in physical impacts to the environment." (Staff Report, Exhibit 3, p. 35.) This analysis lacks any consideration of the reasonably foreseeable construction of new hotels from an STR ban which could result in potentially significant impacts to hazards and hazardous materials. Construction of New Hotels Development of new hotels has potential to result in impacts from hazards and hazardous materials present in the locations identified in the General Plan for new hotel accommodations. As discussed in the Addendum, the City includes 555 hazardous materials sites, with 63 active or open sites. (Staff Report, Exhibit 3, p. 34.) The City has not established a baseline condition for hazards and hazardous materials and should explain what hazardous materials are present at the locations for potential hotel development. The City should then explain how hazardous materials will be managed during construction and operation of new hotels. The City also has not explained the baseline condition of contamination at the locations for new hotel development, so the current condition of site soil, soil gas, and groundwater is not clear. The 24