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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 Operation of Existing Hotels The elimination of all STRs in the City is reasonably likely to cause increased demand for existing hotel accommodations in the City. Ramboll concluded the STIR ban could concentrate traffic on roadways going to hotels in the area, since more than half of the hotels in the City are located in one concentrated area of the City, resulting in noise impacts above the City's General Plan Noise Element standard of 65 dBA CNEL, potentially exacerbating existing noise impacts or creating a new noise impact. (Ramboll Environmental Analysis, pp. 9-10.) The City failed to evaluate how the potential noise and nuisance complaints associated with hotels may be greater than those associated with STRs. To understand the potential impacts from increased use of existing hotels, the City should calculate the total noise complaints associated with STRs it has received, and the total noise complaints associated with hotels, to understand if there is any appreciable difference between the noise complaints received from these accommodations. The City also failed to analyze how this increased demand could lead to potentially significant operational noise impacts from visitors using the facilities, including outdoors areas of hotels such as pools and recreation areas. The City must analyze these potential impacts from the increased use of existing hotels. In addition, it is likely that restricting the use of STRs would require patrons to stay at a hotel or other facility that is further from their intended destination, again resulting in increased VMT, and potentially higher noise levels from increased traffic. As discussed in the technical environmental analysis prepared by Ramboll, shifting traffic to residential or other noise-sensitive areas within the City that are currently below the City's noise threshold could result in a significant impact. The City must evaluate this potential impact. Construction of New Hotels Ramboll estimates the STIR ban will potentially cause significant noise impacts related to hotel construction, exceeding the City's General Plan Noise Element standard and the City's noise ordinance. (Ramboll Environmental Analysis, pp. 11-12.) Construction equipment including heavy machinery can result in significant noise impacts, with sound levels ranging from approximately 75 to 90 dBA (typical suburban/urban background sound levels are commonly on the order of 45 to 55 dBA during daytime hours and lower during nighttime hours) assuming typical receptor distances of 500 ft to 50 ft, and construction may sometimes need to occur at night due to various limitations or time constraints, which may be particularly prevalent over the next few years as hotel construction in Southern California increases to meet hotel demand for the 2028 Olympics. (Ramboll Environmental Analysis, p. 13.) Because sound pressure levels from construction of new hotels, which will be needed due to the STIR ban, have the potential to cause a temporary increase above the noise level threshold, the City must conduct further analysis to evaluate potentially significant impacts and any necessary mitigation. (Ramboll Environmental Analysis, pp. 13-14.) The City should prepare an analysis to quantify projected noise levels from construction of the new hotels in the designated areas identified in the General Plan, Specific Plans, and Zoning Code for hotel development. This analysis should be based on specific parameters for the proposed new uses being 28