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NOP Comments RE:Related Bristol Specific Plan April 17,2023 Page 4 of 4 Sixth, the Citvshould also consider hotel-specific recycling and traffic demand management f"TDM") programs to further reduce the environmental impacts associated with a hotel operation. For example,the City should consider hotel-specific recycling programs that promote recycled paper and other products like soap.ls Additionally, hotels can include a robust traffic demand management("TDM") program that includes full transit subsidies, participation in guaranteed ride programs,employee carpool/vanpool access to preferential parking spaces and/or hotel valet service,and dedicated shuttle service for hotel patrons towards nearby destinations.16 Seventh, to the extent the City considers approving a Proiect that will result in significant unavoidable impacts, the City must adopt a "statement of overriding considerations"finding that the project's benefits outweigh its environmental harm. (See e.g., CEQA Guidelines§ 15043; Pub. Res. Code§ 21081(b).17) Pub. Res. Code§ 21081 makes clear that overriding considerations can include: "Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities for highly trained workers, [which] make infeasible the mitigation measures or alternatives identified in the environmental impact report."(Id., subd. (a)(3).) In closing,thank you for this opportunity to provide these NOP comments. Local 11 looks forward to participating in the CEQA review process and working cooperatively with the City to ensure the Project is environmentally responsible and provides adequate public benefits. This office requests all notices concerning any CEQAlland use actions involving the Specific Plan, Project, and Project Approvals as required under applicable law. (See e.g., Pub. Res. Code§§ 21092.2, 21167(f); Gov. Code§ 65092.)We also ask that the City place this office on the notification list for the Project and Project Approvals. Please send notice by electronic and regular mail and inform us of any fees associated with this request. Thank you for consideration of these comments.We ask that this letter be placed in the Project's administrative record. Sincerely, LAW OFFICE OF GIDEON KRACOV i Jordan R. Sisson Attorney for UNITE HERE Local 11 1s See e.g.,https://www.nytimes.com/2022/05/17/travel/clean-the-world-hotel-soap.html; https://freakonomics.com/podcast/the-economics-of-everyday-things-used-hotel-soaps/; https://cleantheworld.org/;https://calrecycle.ca.gov/organics/food/restaurants/; https://cleanriver.com/blog-launch-hotel-recycling-program/;https://calrecycle.ca.gov/epp/greenlodging/. 16 See e.g.,Santa Monica Municipal Code§9.5.130(B)(2)(b);https://www.octa.net/getting- around/rideshare/oc-rideshare/employers/guaranteed-ride-home-program/; https://www.ci.healdsburg.ca.us/AgendaCenter/ViewFile/Item/3098?fileID=21731; 17 See also Concerned Citizens ofS. Central LA v.Los Angeles Unif.Sch.Dist.(1994) 24 Cal.AppAth 826,847; Sierra Club v. Contra Costa County(1992) 10 Cal.AppAth 1212, 1222.