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<br />1to make up for the loss in overnight accommodations STRs currently provide, and urban decay if <br /> <br />2 the ban ultimately results in homeowners being unable to afford their homes and causing <br /> <br />3 businesses to shutter from the decline in tourism and transitory resident revenue. <br /> <br />4 51. On April 16, 2024, the City Council ultimately approved the STR Ban <br /> <br />5 consent,deliberation on the topic. In doing so, the City Council <br /> <br />6 concluded that the STR Ban . The City did not address the letters <br /> <br />7 arguing otherwise. And having concluded the STR Ban failed to <br /> <br />8 conduct any environmental review. <br /> <br />9 Ordinance No. NS-3061 Did Not Exempt Existing Lawful STRs from the Ban <br /> <br />10 52. The STR Ban completely prohibits STRs throughout the City and did not provide <br /> <br />11 any grandfathering, amortization, or just compensation for existing, lawfully operating STRs. As <br /> <br />12 explained above, the City took this action despite correspondence provided to the City Council <br /> <br />13 informing it that the blanket ban on STRs in the City would have a drastic economic impact on <br /> <br />14 STR owners. Rental Alliance members will face these drastic impacts. The City has placed STR <br /> <br />15 owners and operators in an untenable economic position. Not only will the properties face <br /> <br />16 decreasing value, owners could also be forced to sell their homes due to the immediate loss of STR <br /> <br />17 income and the inability to maintain mortgages, and operators will immediately lose their <br /> <br />18 established business and livelihood. <br /> <br />19 <br /> <br />20 FIRST CLAIM FOR RELIEF <br /> <br />(Writ of Mandate Due to Failure to Comply with CEQA Code of Civil Procedure <br />21 <br />§§ 1085, 1094.5 and Public Resources Code §§ 21000 et seq.) <br /> <br />22 <br />53. Petitioner incorporates by reference all preceding paragraphs as though set forth <br /> <br />23 <br />fully herein. <br /> <br />24 <br />54. An actual and justiciable controversy has arisen and now exists between Petitioner <br /> <br />25 <br />and the City, concerning whether the CityCalifornia <br /> <br />26 <br /> <br />27 <br /> <br />28 <br /> <br /> <br /> <br /> VERIFIED PETITION FOR WRIT OF MANDATE <br />AND COMPLAINT <br />15 <br /> <br /> <br />