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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 household supplies. As discussed above, STRs compete with hotels by offering a different sort of service with a unique structure, and STRs "pop up throughout cities where there is demand for lodging. They do not require centralization. . . Rentals offer a more sustainable option that requires fewer resources and helps increase access with more diverse accommodation options and better value."45 Further, STRs "are critical to regional economies, offering unique and affordable experiences to visitors, generating significant tax revenue to support local governments, and providing hosts significant income."as An STR ban could have devastating effects on local businesses, including restaurants and small businesses,that are not in the areas where hotels exist or would be developed.As set forth in the Economic Prosperity Element of the City's General Plan, the City has established goals of attracting businesses to "strengthen and expand citywide business attraction efforts in order to achieve the city's full employment potential,"and "stimulate the local economy through tourism.,,47 The City did not analyze any of the potential impacts of an STR ban to this sector of the economy and how this could contribute to urban decay and conflict with the City's General Plan. Potential for lost revenue from tourism is discussed in greater detail in the economic analysis prepared by Ramboll. The City must evaluate this evidence in an EIR. Noise and Vibration Overview Ramboll concluded that there are a number of potentially significant noise impacts that could result from an STR ban and require further analysis by the City. Increased use of existing hotels due to loss of all STRs in the City is reasonably likely to lead to increased operational and traffic noise impacts, which may be significant. Further, it is reasonably foreseeable that additional hotels or other similar facilities would need to be constructed to accommodate patrons who would have previously utilized STRs, and this construction has the potential to result in significant noise and vibration impacts. 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 noise impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 41.) The Addendum does not even discuss potential vibration impacts in its evaluation of the STR ban. (See Id., p. 41.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of noise impacts is insufficient, finding that the STR ban would only affect existing structures, "[n]o impacts related to construction-related noise level increases would occur," and no increases in transportation noise are anticipated. (Staff Report, Exhibit 3, p. 41.) The Addendum does not even address potential vibration impacts from construction of new hotels. The analysis in the Addendum lacks any consideration of the reasonably foreseeable noise impacts resulting from construction and operation of new hotels. 4s King and Jenkins, Unequal Access: Protecting Affordable Accommodations Along the California Coast(2020). 4s Dubetz et al, Staying Power: The Effects on Short-Term Rentals on California's Tourism Economy and Housing Affordability, Milken Institute, p. 1 (2022). 47 Santa Ana General Plan, Economic Prosperity Element, EP 04. 27