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<br />1regulations, development standards, building codes, permit procedures, and other local policies), <br /> <br />2 and environmental factors (adequacy of infrastructure, public services, and water supply to support <br /> <br />3 new development). <br /> <br />4 94. On top of all of this, the City failed to follow CEQA requirements when it hastily <br /> <br />5 approved this extreme measure. <br /> <br />6 95. In short, the City adopted the STR Ban without studying the relationships between <br /> <br />7 STRs and public health and safety or long-term housing availability. That, combined with the <br /> <br />8 error of law and complete disregard for CEQA and existing law governing treatment of existing <br /> <br />9 nonconforming uses, arbitrary, capricious, entirely lacking in evidentiary <br /> <br />10 support, or unlawfully or procedurally unfair. <br /> <br />11 96. This approach does not meet the standard for informed, rational decision making <br /> <br />12 required, and the City therefore abused its discretion as a matter of law. <br /> <br />13 97. Petitioner respectfully requests that the Court set aside the adoption of Ordinance <br /> <br />14 No. NS-3061 as an abuse of discretion, and remand the matter to the City to undertake the required <br /> <br />15 review of the relevant law and evidence. <br /> <br />16 PRAYER FOR RELIEF <br /> <br />17 Wherefore, Petitioner prays for relief as follows. <br /> <br />18 1. For the First Cause of Action for Writ of Mandate due to Failure to Comply <br /> <br />19 with CEQA: <br /> <br />20 i. A writ of mandate directing the City to rescind and set aside its approval <br /> <br />21 of Ordinance No. NS-3061; <br /> <br />22 ii. An injunction restraining the City and its agents, servants, and <br /> <br />23 employees, and all others acting in concert with the City, from taking <br /> <br />24 any action to implement Ordinance No. NS-3061 pending full <br /> <br />25 compliance with the requirements of CEQA, the Guidelines, and all <br /> <br />26 other applicable laws and regulations; <br /> <br />27 <br /> <br />28 <br /> <br /> <br /> <br /> VERIFIED PETITION FOR WRIT OF MANDATE <br />AND COMPLAINT <br />25 <br /> <br /> <br />