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dFCAJA Environmental Services, LLC 9410 Topanga Canyon Blvd.,Suite 101 Chatsworth,CA 91311 Phone 310-469-6700 Fax 310-806-9801 both from existing hotels, and from potential new hotels, an STR ban could result in significant impacts to utilities and services systems. 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 utilities and service systems impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 48.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of impacts to utilities and service systems from the STR ban is insufficient, finding that the STR ban would only affect existing structures, and that the ban "would not require development of any kind" so there would be no increase in demands to utilities and service systems. (Staff Report, Exhibit 3, p. 48.) The analysis in the Addendum lacks any consideration of the reasonably foreseeable impacts to utilities and service systems resulting from operation of existing and new hotels. Operation of Existing Hotels - Water By increasing visitor demand for existing hotels, an STR ban has potential to result in increased demand for water, electricity, and natural gas, and the increased generation of wastewater and solid waste, which could result in the need for the construction or expansion of water or wastewater treatment facilities, landfills, storm water drainage facilities, electric power facilities, natural gas facilities, or telecommunications facilities. STR guests use the typical amount of water used in a residential home, which is substantially less water than hotel guests.52 According to the 2018 Cleantech analysis, by staying in Airbnb listings rather than hotels in 2017, Airbnb guests in Europe reduced water usage equal to 13,000 Olympic-sized swimming pools. Because an STR ban will eliminate all STRs in the City, it is reasonably foreseeable that the number of guests staying in higher water use facilities like hotels will increase resulting in a greater demand for water. Water efficiency is a key issue for state policymakers that the City should not discount. California's potable and higher quality, potentially potable irrigation water supplies have been substantially reduced by state and local surface groundwater regulatory constraints and during multiple year droughts notwithstanding the most recent two years of higher-than-normal precipitation. Almost all urban areas of the state do not have sufficient water supplies to meet current and projected future demands over time, and eliminating lower-demand STR uses from the City's overnight accommodations market will place an even greater strain on the City's water supply. In addition, the Conservation Element of the City's General Plan provides that the City should "collaborate with Orange County Water District and Metropolitan Water District to ensure reliable, adequate, and high-quality sources of water supply at a reasonable cost."53 Due to the 52 Airbnb, How the Airbnb Community Supports Environmentally-Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide; Midgett et al., The Sharing Economy and Sustainability:A Case for Airbnb, 13 SMALL BUSINESS INST.J. 2, pp. 61-63 (2017). ss Santa Ana General Plan, Conservation Element, CN 12. 34