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<br />111.First, the Cityimproperly determined that the adoption of OrdinanceNo. NS-3061 <br /> <br />2 California Environmental Quality Ac. The fundamental <br /> <br />3 goal of CEQA is to ensure that decisionmakers and the public have complete information about <br /> <br />4 the environmental impacts of a proposed project before its approval. It does this by requiring public <br /> <br />5 agencies to undertake environmental review of activities, like adoption of land use ordinances, that <br /> <br />6 have the , or a reasonably <br /> <br />7 foreseeable indirect physical change in the environment But the City disregarded this duty and <br /> <br />8 completely failed to conduct any environmental review, despite the fact that the STR Ban would <br /> <br />9 have significant impactsconclusion that the STR Ban was <br /> <br />10 potential direct or indirect physical <br /> <br />11 effect on the environment. As Mark Twain reminds us, the problem with common sense is that <br /> <br />12 By way of example, removing all existing STR accommodations from the <br /> <br />13 centrally located Santa Ana would almost certainly change traffic patterns, and the shifting of <br /> <br />14 traffic from within the City to other locations could have significant environmental impacts, <br /> <br />15 including air quality impacts resulting from increased vehicle emissions from people traveling <br /> <br />16 farther distances to their vacation destinations or temporary/transitory places of employment and <br /> <br />17 residence. The STR Ban provided scant opportunity for public or expert commentary on this issue, <br /> <br />18 but Petitioner and others did comment on the need for an environmental analysis of the STR Ban <br /> <br />19 as required by CEQA. <br /> <br />20 12. Second, the City made unsupported determinations that banning STRs was <br /> <br />21 necessary to preserve public health and safety. But the Staff Report supporting the sweeping <br /> <br />22 prohibitions imposed by the STR Ban did not provide a single specific example of any STR <br /> <br />23 impacting public health or safety in any way. Instead, it relied on less than one page of <br /> <br />24 unsupported characterizations, such as <br /> <br />25 discussing that there were STRs that had received enforcement notice and citations but not <br /> <br />26 providing any detail why those notices were issued or if they had anything to do with public health <br /> <br />27 of safety. <br /> <br />28 <br /> <br /> <br /> <br /> VERIFIED PETITION FOR WRIT OF MANDATE <br />AND COMPLAINT <br />5 <br /> <br /> <br />