Correspondence - Item #15 - Laserfiche WebLink

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