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<br />1in Section 15378 of the CEQA Guidelines, California Code of Regulations, Title 14, Chapter 3 <br /> <br />2 because it has no potential for resulting in physical change to the environment, directly or indirectly <br /> <br />3 <br /> <br />4 63. To the contrary, Ordinance No. NS-3061 could result in direct or reasonably <br /> <br />5 foreseeable indirect physical changes to the environment. With a ban on STRs, guests could be <br /> <br />6 forced to find transient accommodations outside the City limits. The City indicated there are 1,100 <br /> <br />7 active STRs in Santa Ana. Removing all of these existing STR accommodations from the centrally <br /> <br />8 located City could almost certainly change traffic patterns, as visitors to Santa Ana and the <br /> <br />9 surrounding areas could have to seek overnight accommodations elsewhere. This shifting of traffic <br /> <br />10 from within the City to other locations could have significant environmental impacts, including <br /> <br />11 increased vehicle emissions from people traveling further distances across Orange County to their <br /> <br />12 vacation destinations or temporary/transitory places of employment and residence. This could <br /> <br />13 result in air quality impacts to residents of Santa Ana and potential traffic impacts at new locations. <br /> <br />14 Other reasonably foreseeable environmental impacts include, but are not limited to, increased <br /> <br />15 greenhouse gas emissions resulting from the additional vehicle miles traveled, impacts from <br /> <br />16 increased construction of alternative overnight accommodations (hotels and motels) to make up <br /> <br />17 for the loss in overnight accommodations that STRs currently provide, and urban decay if the ban <br /> <br />18 ultimately results in homeowners being unable to afford their homes and causes businesses to <br /> <br />19 shutter from the decline in tourism and transitory resident revenue. <br /> <br />20 64. The City did not evaluate nor disclose to the public these potential significant <br /> <br />21 environmental impacts before adopting Ordinance No. NS-3061 as required by CEQA. Instead, it <br /> <br />22 stopped environmental review of Ordinance No. NS-3061 at the first step in the CEQA decision- <br /> <br />23 making tree, finding without any supporting evidence that the o <br /> <br />24 <br /> <br />25 <br /> <br />26 <br /> <br />27 This is not how CEQA works. The City must find to a certainty that the ban will <br /> <br />28 / / / <br /> <br /> <br /> <br /> VERIFIED PETITION FOR WRIT OF MANDATE <br />AND COMPLAINT <br />18 <br /> <br /> <br />