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dFCAJA Environmental Services, LLC
<br /> 9410 Topanga Canyon Blvd.,Suite 101
<br /> Chatsworth,CA 91311
<br /> Phone 310-469-6700 Fax 310-806-9801
<br /> diverse needs.40 Policy LU-4.3 "encourage[s] land uses and strategies that reduce energy and water
<br /> consumption, waste and noise generation, soil contamination, air quality impact, and light pollution.',4' As
<br /> discussed above, a 2018 Cleantech analysis found that when guests stay at an STIR, significantly less
<br /> energy and water is used, greenhouse gas emissions are lower, and waste is reduced, compared to hotel
<br /> stays42 and an article published in the Small Business Institute Journal also proposed that sharing economy
<br /> based accommodations are likely to consume less energy and water, and produce fewer GHG emissions
<br /> and less waste, than traditional accommodations.43 By removing the ability of hosts to operate STRs from
<br /> existing residences, the City is acting in a manner inconsistent with its Land Use Element policy to
<br /> encourage resources efficient land uses. The City is inappropriately relying entirely on the Land Use
<br /> Element goal of preserving the character of residential neighborhoods, without any substantial evidence
<br /> to demonstrate that STRs in the City are having a negative impact on the character of residential
<br /> neighborhoods and ignoring the other goals and policies of the Land Use Element.
<br /> Construction of New Hotels
<br /> It is reasonably foreseeable that an STIR ban will disperse existing STIR users to other locations that permit
<br /> STRs and induce hotel development. These changes from existing conditions could foreseeably conflict
<br /> with the City's General Plan plans, policies, and regulations, requiring analysis under CEQA as to whether
<br /> there would be a significant environmental impact due to a conflict with a land use plan, policy, or regulation
<br /> adopted for the purpose of avoiding or mitigating an environmental effect.
<br /> The City's General Plan Land Use Element, Policy LU-4.5 aims to "[c]oncentrate development along high
<br /> quality transit corridors to reduce vehicle miles traveled (VMT) and transportation-related carbon
<br /> emissions.,44 As discussed above, the City has identified in its General Plan, Specific Plans, and Zoning
<br /> Code certain locations for hotel development. Many of these locations identified for potential development
<br /> of new hotels may not be centrally located to promote sustainable development, an STIR ban may be
<br /> inconsistent with the City's General Plan.
<br /> Urban Decay
<br /> An STIR ban also has potential to result in urban decay, which the City must analyze. Loss of business
<br /> revenue from tourists unable to secure alternative lodging and unwilling to travel from neighboring areas
<br /> to the City could cause distressing effects in the business community, potentially leading to business
<br /> closures and urban decay.
<br /> The STIR market contributes to the local economy by employing many people, including those working
<br /> pool service, drycleaning, upholstery, catering, bike rentals, yoga studios, transportation, restaurants,
<br /> wineries, tasting rooms, groceries, home repair and improvement, nurseries and landscaping, and
<br /> 41 General Plan, Land Use Element, LU-5.
<br /> 41 Ibid.
<br /> 41 Airbnb, How the Airbnb Community Supports Environmentally-Friendly Travel Worldwide (Apr. 2018),
<br /> https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide.
<br /> 43 Midgett et al., The Sharing Economy and Sustainability:A Case for Airbnb, 13 SMALL BUSINESS INST.J. 2, pp. 61-
<br /> 63 (2017).
<br /> 44 Santa Ana General Plan, Land Use Element, LU-08.
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