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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 Air Quality Overview As discussed in greater detail in the technical environmental report from Ramboll, an STR ban is reasonably likely to significantly impact air quality in several ways, including adverse impacts due to increased VMT of visitors traveling longer distances to reach travel destinations, and from the reasonably foreseeable construction and operation of new hotels to accommodate patrons who would have previously utilized STRs. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance "would not result in any physical impacts on the environment or impacts associated with air quality," and that there would be no change in air quality impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 21.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of air quality impacts is insufficient, finding that that increases in air quality impacts "are based on construction of new structures generating new vehicle trips or population growth." Since the Proposed Ordinance "would only affect existing structures [and] would not induce population growth," there would be no change in air quality impacts beyond those identified in the GP PEIR, and therefore no impacts would occur with respect to air quality. (Staff Report, Exhibit 3, p. 21.) This analysis is entirely superficial, lacking any consideration of the reasonably foreseeable impacts of an STR ban including increased VMT, increased criteria air emissions from hotels within and outside of the City, and construction of new hotels. Air quality impacts are a significant concern for local and state policymakers and agencies. The Conservation Element of the City's General Plan provides that the City should "[p]rotect air resources, improve regional and local air quality, and minimize the impacts of climate change."19 Further, as detailed in the technical environmental report from Ramboll, the STR ban will disproportionately burden environmental justice communities given the City's existing pollution burdens from regional pollution and localized traffic exposure near existing hotel stock, and the potential for increased hotel usage in response to the STR ban. Increased VMT An STR ban is likely to displace a substantial number of existing travelers from overnight accommodations located in closer proximity to travel destinations and residents staying in temporary overnight accommodations located in closer proximity to schools and places of employment. Many families who seek overnight accommodations prefer to stay in STRs for a variety of reasons, since STRs can meet more specialized accommodation needs compared to hotels. Visitors and residents who choose to stay in STRs in other, less regulated areas of Southern California will then have to drive greater distances, consume more energy, and increase criteria air emissions. 19 Santa Ana General Plan, Conservation Element, CN-05. 12