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iCAJA Environmental Services, LLC 9410 Topanga Canyon Blvd.,Suite 101 Chatsworth,CA 91311 Phone 310-469-6700 Fax 310-806-9801 The Environmental Analysis in the Addendum is Deficient Even if an addendum were appropriate, the 51-page Addendum falls far short of appropriately analyzing and disclosing impacts under CEQA. The GP PEIR is silent on STRs and the Addendum contains only a cursory, superficial, and unsupported analysis of the STR ban. The analysis below and the technical environmental and economic analysis provided in the reports from Ramboll, submitted concurrently with this report demonstrate that there are numerous potentially significant environmental impacts that would result from an STR ban in the Proposed Ordinance. These potentially significant environmental impacts also mean the Proposed Ordinance is not eligible for a Class 1 exemption and that the City must prepare a full EIR. This is further clarified in CEQA Guidelines Section 15002(f)(1)which states: (f) Environmental Impact Reports and Negative Declarations. An Environmental Impact Report (EIR) is the public document used by the governmental agency to analyze the significant environmental effects of a proposed project, to identify alternatives, and to disclose possible ways to reduce or avoid the possible environmental damage. (1) An EIR is prepared when the public agency finds substantial evidence that the project may have a significant effect on the environment. (See: Section 15064(a)(1).) Other California jurisdictions have recognized the need to prepare an EIR when proposing STR restrictions. Earlier this year,for example, Monterey County completed an EIR fora proposed set of County regulations for STRs that restricted but did not ban STR uses in the County.An EIR is even more warranted for an ordinance proposing to ban STRs entirely. For the reasons noted below, there is substantial evidence that the City's STR ban will reasonably foreseeably result in direct and adverse changes to the physical environment—including increases in VMT, air pollutants, health consequences, GHGs, and energy use—as well as reasonably foreseeable indirect and cumulative impacts that may result in significant environmental effects. The City cannot rely on the GP PEIR and must prepare a new EIR. In any instance, the Addendum's superficial and conclusory analysis falls short of analyzing, disclosing, and proposing ways to mitigate these impacts and cannot be relied upon to satisfy the City's CEQA obligations. The City must prepare a new EIR, or a new Supplemental EIR to the GP PEIR, to properly analyze all areas of potential significant environmental impact, a reasonable range of alternatives to the Proposed Ordinance, and mitigation of impacts to the maximum extent feasible. 5