Beverly Hills City Council
August 5, 2025

WRITTEN PUBLIC

COMMENTS RECEIVED
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You don't often get email from [email protected]. Learn why this is important From: Huma Ahmed
To: City Clerk
Subject: FW: One Beverly Hills "Big Beautiful Bond"
Date: Thursday, July 31, 2025 11:48:46 AM
From: Helene Harris >
Sent: Thursday, July 31, 2025 11:41 AM
To: 12-Sharona Nazarian <[email protected]>; John Mirisch <[email protected]>; 11-Lester Friedman <[email protected]>; 13-Craig Corman <[email protected]> Cc: WebCBH CITYMANAGER <[email protected]>; Ryan Gohlich <[email protected]>; Huma Ahmed <[email protected]>; ; Gross Josh >
Subject: One Beverly Hills "Big Beautiful Bond"
Good morning all.

Please read the following into the public comment portion of the City Council meeting on August 5th:

August 19th agenda item: two words: Final approval? A $550,000,000 bond issuance by our City to help a developer? How is this even possible? Huge thank you to Peter Ostroff, for his Weekly Short Takes article or we, the residents of Beverly Hills, might not have heard about this until after the fact.

And thank you, Jeffrey Auerbach, for last week’s Letter to the Editor. I totally agreed with his thoughtful argument until the end when he offered the suggestion of a loan. The City of Beverly Hills is not a financial institution, nor is it the City’s responsibility. Why wouldn’t every developer ask for it in the future? Or a business needing a cash infusion? Hell, I’m thinking about buying a new car…
That project is no more ambitious today than it was all those years ago when Oasis LLC desperately lobbied the community in a referendum, complete with an army of lobbyists, catered meetings and Tiffany party favors. The developer, the architect, and the financiers all knew the project needed infrastructure. Shucks, even I knew it needed infrastructure, and I’m just someone who enjoys the luxury of electricity and water running through my house.

So what’s changed? Well, when I attended an earlier OBH iteration’s dog and pony show, they were expecting that the 6 and 7 bedroom condos they were building would attract wealthy foreigners, oligarchs, and such, and be used as a pied-â-terre, allegedly not impacting traffic and, wait for it, infrastructure. Another difference? Time has not been kind to this project.

Construction costs have probably sky rocketed, with supply tariffs and unforeseen labor costs.

I do not see any upside for the residents in providing this bond. If there were an upside, we would have heard about it.

So please, explain to me how this bond serves the residents? Helene Hartris
From: Darian Bojeaux
To: City Clerk
Subject: Consent Calendar E 11 and G 3--City Staff Raises Date: Tuesday, August 5, 2025 5:51:57 PM
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Please read my comment at tonight’s meeting.

Thank you.

Darian
Good evening.

Although I understand that we are facing a $20 million annual budget deficit for 2 years in a row, about $40 million. somehow the city attorney has seen fit to recommend a 7% raise for our city clerk, $15,621, so that she will be earning about $239K instead of about $223K, and a 7% raise for our city manager, $29,065 so she will be earning about $444K instead if about $415K plus her paid living quarters.

Why would we provide raises when our city will be running at a deficit? Even if these two staff members performed their work excellently we cannot afford raises.

I can now see why the city manager has been doing the city attorney’s bidding in attempting in deceptive ways to facilitate the city attorney’s desired change of our procedures manual to allow some formal actions to be taken at study sessions. She complied with his directives so now he is recommending a 7% raise for her.

We should consider that both our city clerk and our city manager make fine, enviable salaries already. Further, given our corrupt U.S. president’s malicious motives toward our state and law-abiding immigrants, among other things, our city’s economy is likely to be harmed even more than we anticipate.

So how about we stop all of the back scratching and run the city properly—spending the money our city can afford —not increasing our city’s debt further.

Darian Bojeaux
TO: MAYOR, VICE MAYOR, AND COUNCILMEMBERS
FROM: STEVE MAYER
DATE: AUGUST 5, 2025
RE: SUPPORT FOR APPLICANT’S REQUEST FOR CONTINUANCE
OF THE APPEAL FOR 412 NORTH OAKHURST
Please permit this communication to support the Applicant’s request for a continuance to a date uncertain for the Appeal of 412 North Oakhurst.

As you may be aware, Rabbi Milikan, the Appellant, asked me to help him with the technical aspects of the Appeal. He is aware of this memorandum and concurs with its contents.

There are a number of reasons why the Applicant’s request should be granted:
(1) CEQA / July 10th Letter: The Applicant is seeking a CEQA exemption via a letter sent to the City on July 10th.

The Appeal focuses, in part, on the CEQA issues.

The Rabbi and his neighbors have to assess how the CEQA components of the Appeal can continue in the hearing, or whether the Appeal will have to be re-worked.
(2) Timely Notice / Lack of Transparency: The Rabbi was not made aware of the significance of the July 10th letter until Saturday evening (because of the Sabbath).
(3) New Law: This is a new area of law.

Because of the Sabbath and The Ninth of Av, it was not possible to consult with attorneys upon a timely basis. Since they are acting in a pro bono capacity, their ability to expediently provide advice is limited. (4) Staff Assertion: Staff has stated that it was not obliged to provide a copy of the July 10th letter to Rabbi Milikan … yet it included a copy in the Agenda packet, as a separate exhibit.

Mayor, Vice Mayor, and Councilmembers
City of Beverly Hills
August 5, 2025

(5) The 5-Meeting Rule:

This is an important consideration, but there is no reason for the Appeal hearing and Staff’s determination as to the July 10th letter cannot be combined into the next hearing.
(6) Applicant / Appellant Concurrence: When an Applicant and the Appellant agree to postpone, the Council usually assents. ___________
An Appeal is supposed to be about “What’s New.”
The July 10th letter and the verbal request for a continuance from the Applicant definitely falls within that category.

Introduction
On June 17th, after his appearance before the Beverly Hills City Council and subsequent medical episode, I visited Rabbi Milikan in the Cedars Sinai Emergency Room. He asked for his assistance with his Appeal of 412 North Oakhurst.

The Appeal focuses on tenant and land use issues. We agreed my assistance would focus upon the technical side of the Appeal
CEQA / July 10th Letter
The Applicant is seeking a CEQA exemption via a letter sent to the City on July 10th (pages 51-55 of the Agenda report).

The Appeal focuses, in part, on the CEQA issues (pages 12-18 of the Agenda report).

The Rabbi and his neighbors have to assess how the CEQA components of the Appeal can continue in the hearing, or whether the Appeal will have to be re-worked.

Mayor, Vice Mayor, and Councilmembers
City of Beverly Hills
August 5, 2025

The request by the Applicant begins:
“This letter provides formal notice to the City of Beverly Hills (the “City”) that the above-referenced project (the “Project”) qualifies for and claims an exemption from the California Environmental Quality Act (“CEQA”) pursuant of Public Resources Code (“PRC”) Section 21080.66, as enacted by Assembly Bill 130 (effective July 1, 2025).” It contains 25 separate detailed points. It cannot be carefully examined in three days.

It has already been established that there were numerous errors in the Application and the previous approval by the Planning Commission by both Staff and the Applicant.

Whether they are minor or significant will be the determination of the Council.

If Staff had provided the July 10th letter upon a timely basis, this would not be an issue, but it did not.

Timely Notice / Lack of Transparency
Because of the Sabbath, the Rabbi was not made aware of the significance of the July 10th letter until Saturday evening.

In turn, the potential of a continuance was mentioned in passing by Staff on Friday afternoon. The Rabbi did not understand the implication, until he was so informed, also on Saturday evening.

Further, the memorialization of the verbal request for a continuance was not included in the Agenda report.

Normally, a request of that nature is made in writing, so Staff can respond in writing. Why that did not occur was not included in the Agenda report.

The City Council continually stresses that it wants both sides to be kept informed upon a timely basis, so issues like this do not arise.

That is from the basis of courtesy, but also the Council’s time will not be wasted.

Mayor, Vice Mayor, and Councilmembers
City of Beverly Hills
August 5, 2025

New Law
This is a new area of law.

AB 130 became effective July 1, 2025, which resulted in a substantial re-working of the Public Resourced Code 21080.

The Applicant timely submitted a detailed 4-page letter on July 10th.

Rabbi Milikan was not provided with a courtesy copy by Staff. Rabbi Milikan became aware of the letter from the Agenda report.

Because of the Sabbath and The Ninth of Av, it was not possible to consult with attorneys upon a timely basis.

Since they are acting in a pro bono capacity, their ability to expediently provide advice is limited.

A greater question is whether AB 130 can be defeated by an Agency or an Appellant?
Staff Assertion
Staff has stated that it was not obliged to provide a copy of the letter to Rabbi Milikan … yet it included a copy in the Agenda packet, as a separate exhibit.

Why would a copy be included if it was not significant? It also implies it was not obliged to inform Rabbi Milikan when the verbal request was received
We disagree. An Appeal is about “What’s New.”
Further in an email yesterday from the Director of Community Development to the author, it stated:

Mayor, Vice Mayor, and Councilmembers
City of Beverly Hills
August 5, 2025

“To clarify, the applicant’s letter dated July 10, 2025, request that a different CEQA exemption be applied to the project but did not include a request to continue the hearing. That request was made verbally at a later date. Since the July 10th letter only addressed the applicability of a new CEQA exemption and did not address the project itself or any issues raised in the appeal, we did not provide Rabbi Milikan with a copy of that letter.”
That is not correct. The Appeal did raise CEQA issues. Beyond Public Resources Code, 21080, AB 130 also impacted other code sections including Government Code Section 65193.

The Applicant’s letter even concludes that “Supporting Documentation” includes:
“Planning Commission Approved Class 32 Categorical Exemption Consistency Analysis, pages 27-46”
Until completely analyzed, this is a mismash.

The 5-Meeting Rule
While the 5-meeting rule is an important consideration, the issues of the Appeal and the July 10th are inextricably linked.

It would be best for the Appeal hearing and Staff’s determination as to the July 10th letter cannot be combined into the next hearing.

Last, Staff has not made clear as to why they feel more than a fifth meeting will be necessary.

It should be further noted that if Title 1, Chapter 4 had not been amended last October, we would not be here.

The changing of a call-up from 30 days to 14 days created an impossible situation in this circumstance due to the December holidays.

If the first hearing had been the date-setting hearing, this would have been concluded long ago.

Mayor, Vice Mayor, and Councilmembers
City of Beverly Hills
August 5, 2025

Applicant / Appellant Concurrence
On a number of occasions in the past decade, when an Applicant and the Appellant agree to postpone, the Council usually concurs.

The Ninth of Av
There has been previous reference to “The Ninth of AV.” It is a colloquial for “Tish B’v.”
Chabad.org describes Tish B’Av as:
“Tish B’Av, the 9th day of the month of Av (August 2-3, 2025) is the saddest day on the Jewish calendar, on which we fast, deprive ourselves and pray. It is the culmination of the Three Weeks, a period of time during which we mark the destruction of the Holy Temple in Jerusalem.”
For a Jewish-sensitive City, Rabbi Milikan was very surprised that Staff was either unaware or insensitive to the importance of Tish B’Av.

It was the reason why the Rabbi initially requested the continuance to be at the second meeting in August, so as not to conflict with such an important historical observance.

Aug 5, 2025
City of Beverly Hills
455 North Rexford Drive, Room 280A
Beverly Hills, California 90210
Re: Proposed Housing Development Project at 412 North Oakhurst Drive By email: [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Cc: [email protected], [email protected], [email protected], [email protected]
Dear Beverly Hills City Council,
The California Housing Defense Fund (“CalHDF”) submits this letter to remind the City of its obligation to abide by all relevant state housing laws when evaluating the proposed 52-unit residential building at 412 North Oakhurst Drive, which includes 12 units located within Beverly Hills and 40 units located in Los Angeles. The project contains 10 affordable units, three of which would be located in Beverly Hills (two very low-income units, and one low-income unit). These laws include the Housing Accountability Act (“HAA”), the Density Bonus Law (“DBL”), and California Environmental Quality Act (“CEQA”) guidelines.

The HAA provides the project legal protections. It requires approval of zoning and general plan compliant housing development projects unless findings can be made regarding specific, objective, written health and safety hazards. (Gov. Code, § 65589.5, subds. (d), (j).) The HAA also bars cities from imposing conditions on the approval of such projects that would render the project infeasible (id. at subd. (d)) or reduce the project’s density (id. at subd. (j)) unless, again, such written findings are made. As a development with at least two-thirds of its area devoted to residential uses, the project falls within the HAA’s ambit, and it complies with local zoning code and the City’s general plan. Increased density, concessions, and waivers that a project is entitled to under the DBL (Gov. Code, § 65915) do not render the project noncompliant with the zoning code or general plan, for purposes of the HAA (Gov.

Code, § 65589.5, subd. (j)(3)). The HAA’s protections therefore apply, and the City may not reject the project except based on health and safety standards, as outlined above.

Furthermore, if the City rejects the project or impairs its feasibility, it must conduct “a 2201 Broadway, PH1, Oakland, CA 94612
www.calhdf.org
F-1
thorough analysis of the economic, social, and environmental effects of the action.” (Id. at subd. (b).)
CalHDF also writes to emphasize that the DBL offers the proposed development certain protections. The City must respect these protections. In addition to granting the increase in residential units allowed by the DBL, the City must not deny the project the proposed waivers and concessions with respect to minimum unit size, paving of setbacks/walkways, building height, side setbacks, front setback, and outdoor living space. If the City wishes to deny requested waivers, Government Code section 65915, subdivision (e)(1) requires findings that the waivers would have a specific, adverse impact upon health or safety, and for which there is no feasible method to satisfactorily mitigate or avoid the specific adverse impact. If the City wishes to deny requested concessions, Government Code section 65915, subdivision (d)(1) requires findings that the concessions would not result in identifiable and actual cost reductions, that the concessions would have a specific, adverse impact on public health or safety, or that the concessions are contrary to state or federal law. The City, if it makes any such findings, bears the burden of proof. (Gov. Code, § 65915, subd. (d)(4).) Of note, the DBL specifically allows for a reduction in required accessory parking in addition to the allowable waivers and concessions. (Id. at subd. (p).) Additionally, the California Court of Appeal has ruled that when an applicant has requested one or more waivers and/or concessions pursuant to the DBL, the City “may not apply any development standard that would physically preclude construction of that project as designed, even if the building includes ‘amenities’ beyond the bare minimum of building components.” (Bankers Hill150 v. City of San Diego (2022) 74 Cal.App.5th 755, 775.)
Additionally, the project is exempt from state environmental review under the Class 32 CEQA categorical exemption (In-Fill Development Projects) pursuant to section 15332 of the CEQA Guidelines, as the project is consistent with the applicable general plan designation and all applicable general plan policies as well as the applicable zoning designation and regulations; the proposed development occurs within city limits on a project site of no more than five acres substantially surrounded by urban uses; the project site has no value as habitat for endangered, rare, or threatened species; approval of the project would not result in any significant effects relating to traffic, noise, air quality, or water quality; and the site can be adequately served by all required utilities and public services. Furthermore, the project is eligible for a statutory exemption from CEQA pursuant to AB 130 (Pub. Res. Code, § 21080.66), which was signed into law on June 30, 2025 and effective immediately (Assembly Bill No. 130, 2025-2026 Regular Session, Sec. 74, available here). Caselaw from the California Court of Appeal affirms that local governments err, and may be sued, when they improperly refuse to grant a project a CEQA exemption or streamlined CEQA review to which it is entitled. (Hilltop Group, Inc. v. County of San Diego (2024) 99 Cal.App.5th 890, 911.) As you are well aware, California remains in the throes of a statewide crisis-level housing shortage. New housing such as this is a public benefit: by providing affordable housing, it 2 of 3
will mitigate the state’s homelessness crisis; it will bring new customers to local businesses; it will grow the City’s tax base; and it will reduce displacement of existing residents by reducing competition for existing housing. It will also help cut down on transportation-related greenhouse gas emissions by providing housing in denser, more urban areas, as opposed to farther-flung regions in the state (and out of state). While no one project will solve the statewide housing crisis, the proposed development is a step in the right direction. CalHDF urges the City to approve it, consistent with its obligations under state law.

CalHDF is a 501(c)(3) non-profit corporation whose mission includes advocating for increased access to housing for Californians at all income levels, including low-income households. You may learn more about CalHDF at www.calhdf.org.

Sincerely,
Dylan Casey
CalHDF Executive Director
James M. Lloyd
CalHDF Director of Planning and Investigations
3 of 3
250 East 1st Street, Suite 1201; Los Angeles, California 90012 213.336.5900  betterneighborsla.org
August 4, 2025
City of Beverly Hills City Council
455 North Rexford Drive
Beverly Hills, CA 90210
[email protected]
Via Electronic Mail
Re: Better Neighbors LA – Agenda Item E-7: Ordinance Amending Short Term Rental Regulations– Support
Dear Mayor Nazarian and Honorable Councilmembers,
Better Neighbors LA is a coalition of tenants, housing advocates, and community members committed to protecting long-term housing by curbing illegal short-term rental (“STR”) activity. Through data analysis and research, we assess the STR industry’s impact on affordable housing and local neighborhoods. We write in strong support of the proposed ordinance amending STR regulations, which prohibits STRs in all residential units, establishes a one-year minimum lease, and creates a penalty schedule that sets fines to the maximum extent allowed under state law.

Following extensive deliberation by the Planning Commission, city staff, and this Council, the ordinance makes strides in preserving Beverly Hills’ housing stock for long-term renters and mitigating the wide-ranging harms associated with STRs including nuisance complaints, loss of privacy, safety risks, and enforcement challenges. We commend the Council for strengthening the ordinance by standardizing a 1-year minimum lease across all residential zones, which will improve enforcement and housing stability for Beverly Hills’ renter majority.

Additionally, the inclusion of a private right of action clause empowers those who collect or remit Transient Occupancy Tax (“TOT”) to pursue legal remedies against non-compliant STR operators and platforms. This provision would bolster enforcement capacity and deter illegal activity.

The comprehensive STR ban paired with a one-year minimum lease, a private right of action, and a rigorous enforcement mechanism will help preserve City resources, protect residents from the negative effects of short-term rentals, and safeguard long-term residents from increasing housing costs and the threat of displacement. For these reasons, Better Neighbors LA urges the City Council to adopt the ordinance without further delay. Should you have any questions or would like additional information, please contact Maura O’Neill at [email protected].

Sincerely,
/s/ Randy Renick
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From: RUBI MAL
To: WebCBH MAYORANDCITYCOUNCIL; City Clerk
Subject: 412 North Oakhurst Appeal - Applicant"s Request For Continuance Date: Sunday, August 3, 2025 1:41:20 PM
Honorable Mayor, Vice Mayor, and Councilmembers:

We are in support of the Applicant's request for a continuance.

We were unaware of the July 10th letter (pages 51-55 of the Agenda Report) until reviewing the Agenda Report on Friday afternoon.

We were not informed of the Applicant's request for a continuance until it was mentioned in passing during a meeting with Ryan on Friday afternoon.

In our meeting with the Dr. Nazarian and Michael Forbes on Thursday afternoon, the request for continuance was not mentioned.

The potential impact of the July 10th letter could be significant to the Appeal, and it should be considered in total with the Appeal, not as an adjunct.

Relative to the 5-meeting rule, we do not feel that should not be the determining factor. It simply means that a referral back to the Planning Commission would not be available. In the case of the "Stinking Rose" call-up. the City Council added several conditions (beyond the Planning Commission's), which could also occur with 412 North Oakhurst.

With blessings and appreciation.

Rabbi Ruben Milikan
1 July 28, 2025
Dear Beverly Hills City Council, Planners and Staff:

I know I am late to the game in regards to your proposed STR ban for Beverly Hills.

I read a news article that alarmed me enough to watch the full portion regarding short-term rentals (STRs) in your July 1, 2025 City Council meeting.

What I saw troubled me so much that it prompted me to spend the weekend writing this letter even though I do not benefit in any way from the City’s final decisions.

Background and Personal Experience
I am someone who has personal experience on both sides of the STR issue.

I lived in a “Sea of STRs” in another city (Hermosa Beach) from 2005-2010.

After living a comfortable middle-class life, I was suddenly facing near medical bankruptcy in 2010.

I had to move out of my home and convert my beachfront property into a short-term rental from 2010 until 2016 just to make ends meet.

I was forced to stop when Hermosa Beach passed an ordinance banning STRs in residential zones without the required Coastal Commission approval, effectively an illegal ban under coastal law.

Despite this, the City has continued to enforce it aggressively and is now facing an active lawsuit by another resident.

My personal history gives me a unique perspective: I know what it’s like both to live surrounded by STRs and to operate one as a means of financial survival.

One morning in 2005, I woke up to find that four of the six units in my own building had become short-term rentals, along with six more units in adjacent buildings and at least six others further down the block. It had happened practically overnight.

I initially feared the worst. I worried about the kinds of issues people often complain about, such as noise, strangers, trash, loud parties, parking, and privacy.

But I was fortunate that all of those STRs were managed by responsible hosts.

My neighboring STR operators at the time self-regulated out of fear that Hermosa Beach would formalize a ban.

Within a few weeks, it became a complete non-issue.

I virtually forgot they were STRs and lived peacefully beside them for the next five years. 2 Observations from the July 1 Meeting and Suggested
Carve-Outs
At your July 1 City Council meeting, I was struck by a public comment from a homeowner named Deborah Blum.

Ms. Blum and a friend explained that they had heavily invested in a designated historic home and depended on STR income, renting out a guest house on the property, to survive financially.

I was impressed by how the entire Beverly Hills City Council listened to her concerns, called her back up for clarifying questions, and discussed carving out an exception for people in her specific situation.

But on the other side of the coin, Ms. Blum was fortunate to find out about the meeting and that she was able to speak as eloquently as she did.

I am certain many others are in similar situations and may not have known about the meeting at all.

There are likely other Beverly Hills homeowners, not living in historic homes, who are also facing financial hardship.

For some, the ability to rent out a room or an Accessory Dwelling Unit (ADU) as an STR could mean the difference between keeping their home or facing foreclosure.

While Beverly Hills currently has a low foreclosure rate, that could change as economic conditions shift due to inflation, rising healthcare costs, or global trade disruptions.

Allowing some limited STR activity could serve as a safety valve for residents in need.

It troubles me that the decisions made that night were shaped entirely by those few who were able to attend and speak.

My suggestions:

To address additional cases like Ms. Blum’s and mitigate potential hardships while still protecting neighborhoods, the City could create specific carve-outs and regulations, such as:
• Properties In or Adjacent to Commercial Areas:

Permit STRs in certain zones (or specific properties) adjacent to commercial or entertainment districts where transient use would be less disruptive.

This would focus STR activity on areas where visitors naturally congregate, reducing impact in quiet residential interiors.
• Hardship-Based STR Permits:

Allow homeowners to apply for a hardship exemption to operate an STR if they can demonstrate genuine financial need (for example, seniors on a fixed income, individuals with medical crises, etc.).
• Owner-Occupied STRs (Home-Sharing):

While some communities only allow STRs when the host remains on site (“hosted” rentals), I caution that making STRs hosted-only, as some cities do, is not a complete solution.

Hosting only while the owner is present (like Ms. Blum’s case renting a guest house 3 with oversight) may reduce certain nuisance risks, but it also excludes many legitimate scenarios.

For example, an owner who must travel for work or temporarily relocate should not be disqualified from operating a legal STR simply because they are not physically on site during that period.

A family would not want to rent an entire home that requires the owner to be onsite.

Nor should a homeowner be forced to stay in the same home with their renters.

Likewise, many second homes in Beverly Hills sit vacant for much of the year, allowing those to be used as STRs, even if not owner-occupied during guest stays, could actually bring life and revenue to the city without displacing any long-term renter.

Hosted rentals can be one option, but they should not be the only permissible type of STR.
• Multifamily Building Restrictions:

I agree with your Planning Department’s suggestion that multi-family condominiums or apartments with controlled-access entry should generally not be used for STRs, as this is often addressed in CC&Rs or leases already.

An ordinance could codify that STRs are not allowed in multi-unit buildings unless the HOA or building explicitly permits it.
• Mid-Term Rental Allowances:

The Council discussed allowing rentals of less than a year for certain groups like visiting doctors, nurses, or people on short-term work assignments.

Please follow through on creating a legal path for these mid-term stays (under 12- month leases).

Moreover, local residents often need temporary housing due to home renovations, fire or flood damage, or other disruptions.

These stays may last a few weeks to months, not a full year.

Your policies should account for these situations to ensure displaced residents can remain in the community during that time, especially if their children are enrolled in local schools.

One important note from my own experience: when Hermosa Beach’s ban forced me to switch from short vacation stays to 30-day minimum rentals, I remained virtually complaint-free.

In fact, an owner-occupant neighbor in our six-unit building recently told me she never once had an issue with any of my 30-day renters over the past ten years.

Ironically, her only complaint was about another owner who used his unit as a second home.

It often sat empty, except when he allows his 18-year-old son to stay there with friends and throw loud weekend parties.

This illustrates that the problem is behavior, not length of stay.

A long-term tenant or even an owner-occupant can be a bad neighbor, while a short-term guest can be perfectly respectful.
4 Notably, if a short-term guest causes trouble, the host can act quickly to remove them, provided the stay is under 30 days.

In contrast, dealing with a problem long-term tenant often requires a formal eviction process that can take several months, during which the disruptive behavior usually continues.

And if your bad neighbor is the owner and lives there, forget it. You may be stuck with them indefinitely.

Beverly Hills already has a strict noise and nuisance ordinance to prevent large parties.

A compliant permitted STR operator has every incentive to enforce those rules on their guests, because their permit and income are at stake.

In contrast, a traditional landlord has less immediate control once a lease is signed and the tenant has stayed longer than 30 days.

Additionally, I suggest including wording in your ordinance to allow emergency or disasterrelated STR stays.

For example, when the nearby wildfire hit Los Angeles in 2018, Beverly Hills wisely suspended its 30-day minimum rental rule temporarily to allow displaced fire victims to find short-term housing.

In my own case, having my home available as a 30-day minimum rental gave several displaced families the opportunity to find a place to stay.

I ended up hosting multiple families over the following months who had lost everything.

In addition, Airbnb subsidized those stays for the families.

An ordinance could explicitly permit short-term rentals during declared emergencies or natural disasters, ensuring that victims and relief workers can secure local housing on short notice.

This kind of flexibility is a humanitarian measure and would reflect well on the City.

Addressing the Reasons Behind the Proposed Ban
From the July 1 meeting and subsequent news coverage, I gathered that the Council’s rationale for moving toward a complete ban on STRs revolves around a few key concerns:
party houses and neighborhood nuisances; loss of tax revenue and hotel business; and impacts on housing availability.

These are valid concerns.

However, I believe these issues stem from the way STRs have been handled, or not handled, up to this point.

The real problem is the lack of sensible regulations, not the concept of STRs themselves.

I’d like to address each of these points based on data, research, and my firsthand experience.
5 ‘Party Houses’ and Nuisance Complaints
Councilmember Craig Corman spoke at the meeting, saying that “party houses” were partly to blame for the City’s decision to move toward a ban on short-term rentals.

I absolutely agree that so-called “party houses” are a serious problem.

No neighborhood should have to tolerate a revolving door of loud, late-night parties in a residential setting.

But I disagree that banning all STRs is the only solution to this problem.

It is very possible to allow STRs while strictly preventing party houses, if the City implements the right rules and enforcement.

First, most responsible STR hosts themselves do not want parties in their properties.

Such guests cause serious damage to the home, disturb neighbors, and attract negative attention from authorities, all things a good host strives to avoid.

When I operated my STR, I explicitly forbade parties or events and set quiet hours, precisely because I wanted to protect my home and keep peace with neighbors.

The platforms also allow hosts to screen guests by reviewing their prior ratings and communicating before booking.

A one-night rental to a local 22-year-old looking to host 50 friends is a scenario any diligent host will reject.

For example, if I see a booking request from a family of four from Nebraska for a week, that’s likely fine, but a group of six college frat boys raises red flags.

Blanket assumptions that any one-night booking equals a blow-out party are not accurate; careful vetting and a two-way review system help prevent many problems.

Of course, there will always be a few bad actors, hosts who negligently or even willfully rent out “party houses” to anyone.

Those few can and should be dealt with individually through enforcement, rather than taking away the privilege of responsible hosting from everyone.

With a robust STR regulation ordinance (e.g. requiring registration, setting occupancy limits, noise monitoring, and hefty fines/permit revocation for violations), those operators will either straighten up or be shut down quickly.

Airbnb itself has taken steps to crack down on such rentals in recent years, and cities can partner with platforms on this issue.

The bottom line is we don’t ban all bars because one bar occasionally has a rowdy patron, we enforce the rules on the ones causing trouble.

Similarly, we shouldn’t ban all STRs because a few owners allowed parties; we should enforce against the offenders.
6 Allow me to share an illustrative incident. During my six years of hosting STRs, mostly involving three-to-five-day stays, I had hundreds of bookings with no serious issues.

However, there were two cases where neighbors did complain. • Case 1: The Unapproved Party.

A renter booked my place claiming it was for a small family gathering.

It turned out to be a group of six twenty-something young men.

I was immediately wary at check-in and reiterated to them my strict no-parties rule and the consequences.

At the time, our six-unit condo building had multiple STR units, all of which were legally operating at the time, along with a couple of owner-occupied units.

Sure enough, by 8PM that night I started getting complaints of loud music and a gathering, interestingly, not from the two owner-occupants, but from the other STR hosts in the building.

Those fellow hosts were upset because they feared this one bad rental would ruin things for everyone and prompt the City to crack down.

Ironically, one of the owner-occupants even went over and joined the party.

I gave the group three warnings to shut it down, which they ignored.

Finally, I drove over in person, confronted them with the rental agreement, and told them the party was over.

I changed the lock code and evicted them on the spot for breaching the contract.

I also kept their security deposit and the rent for the remaining nights, a financial penalty on top of the immediate eviction.

The party was stopped within a few hours of it starting.

I did have to repair a couple of damaged walls and clean up after them, and needless to say, I left them an awful review so no one else would rent to them.

But importantly, that swift action prevented further disturbance.

If those were long-term tenants causing a disturbance to my neighbors, I would have been stuck with a drawn-out eviction process; as an STR host I had the leverage to remove them immediately.
• Case 2: Minor Nuisance.

In another instance, a middle-aged woman rented my home along with a few of her old high school girlfriends for a quiet reunion week, or so they claimed.

They did keep things low-key in terms of noise, and there were no noise complaints during the stay.

However, I learned afterward that their “girl talk” sessions each evening involved heavy cigarette smoking out on the patio and leaving butts on the ground.

A neighbor mentioned the litter to me after they’d checked out.

This wasn’t a wild party at all, just a bit of inconsiderate behavior.

I apologized to the neighbor and later updated my house rules to address proper disposal of smoking materials.

This was an isolated incident unrelated to any inherent issue with STRs.

It could just as easily have happened with long-term renters or houseguests.

Still, I learned from it and adjusted my rental agreement accordingly. 7 The reason I share these stories is to show that even without a ban, problems can be addressed on a case-by-case basis.

In the first case, the system worked.

As the host, I had both the incentive and the ability to immediately shut down the party and make sure it wouldn’t happen again.

In the second case, a minor nuisance was resolved with better communication and an update to my rental agreement.

Out of six years of year-round rentals, these were the only two isolated notable incidents, a pretty good track record.

Most STR guests are vacationing families, couples, or business travelers who are respectful.

They are your friends and your families wanting to stay close to you.

Responsible hosts screen out the bad apples.

With sensible regulations in place, “party houses” can be eliminated without eliminating all STRs.

Tax Revenue and Hotel Competition
Mr. Corman also cited lowered tax revenue and loss of business to area hotels in his statement on the proposed ban.

It’s true that if a visitor stays in an illegal STR, the City currently misses out on Transient Occupancy Tax (TOT), and hotels lose a booking.

But from the City’s perspective, banning STRs outright is not the only way to address this.

In fact, a well-regulated STR program can increase tax revenue while co-existing with hotels.

As noted during the meeting, Beverly Hills rarely sees any TOT remitted from STRs today because those rentals operate outside of a formal permitting system, which the City does not currently have.

The obvious remedy is to bring STR operators into the fold through a legal permit system.

A STR owner would be required to pay a permit fee to the City, collect and remit TOT, and adhere to rules.

Major platforms like Airbnb and VRBO have built-in systems to automatically collect and pay TOT to cities on behalf of hosts, once an ordinance is in place, so compliance can be made relatively easy.

In my experience, compliant hosts want to pay the taxes and follow the rules if it means they can operate legitimately without fear of punishment.

A City-issued STR permit would be valuable; losing it would mean losing their income source and their investment in the property to make it an STR, such as furniture, linens, installing storage lockers, cleaning and vanity items.

Therefore, permit holders have a powerful incentive to follow noise, occupancy, and tax rules to protect their permit, just as bar owners zealously guard their liquor licenses.

I suggest the City institute a robust permit with a substantial annual fee to cover permitting, inspections and enforcement costs.
8 This not only raises revenue but also gives operators “skin in the game” to abide by all regulations.

As for hotels: I strongly believe from experience that traditional hotels and STRs serve different segments of the travel market.

My wife and I, for instance, have never used an STR when vacationing, and we never will.

We always prefer hotels with daily housekeeping, concierge service, room service, and other hotel amenities, and we like staying in established hotel districts.

For example, if we visit Paris, we would choose a hotel near the Louvre rather than a STR deep in a residential area.

Travelers like us will always choose a hotel, and Beverly Hills has plenty of luxury hotel options for that demographic.

However, not every traveler is like us. Nearly all of my short-term rental guests shared their unique reasons for choosing my STR over a hotel during their stay.

There are at least two other groups of visitors for whom an STR is far more appealing, and banning STRs would simply cause those visitors to stay elsewhere rather than in Beverly Hills hotels:

1. Solo travelers or young travelers.

Imagine a backpacker from Norway or a recent college grad who dreams of visiting Beverly Hills.

An $800-per-night hotel like the Beverly Hills Hotel or the Peninsula is out of the question and may be too opulent for their needs.

Such a traveler would be thrilled to rent a spare bedroom in a resident’s home for a reasonable price.

That kind of arrangement benefits the visitor by providing affordable access to the city, and it benefits the host by offering extra income, perhaps to help with their mortgage.

The City also receives TOT from that stay if it’s a legal STR.

Crucially, that traveler was never a potential customer for the luxury hotels, banning STRs won’t send them to the Waldorf-Astoria; it will simply send them to a STR in another city.

In other words, Beverly Hills hotels don’t always lose business when this kind of visitor chooses an STR.

But the City loses out on hosting the visitor and the spending they would have brought to local shops and restaurants if they are instead driven to stay in West Hollywood or Santa Monica.

2. Large families or groups.

There are many situations, including weddings, funerals, reunions, and religious celebrations like bar or bat mitzvahs, where a large extended family travels together or meets up at a destination.

They often want to stay under one roof for convenience and bonding time.

Hotels can rarely accommodate this, except by offering multiple separate rooms, 9 which is not the same as sharing a living room or kitchen together.

Even if a hotel has connecting rooms or suites, the cost of renting three, four, or more hotel rooms for a week, plus eating every meal out, becomes astronomical for an average family.

A single vacation rental home where the whole family can stay together, cook some meals, and have a backyard for the kids, is a vastly more practical and affordable option.

If Beverly Hills bans STRs completely, these groups face a tough choice.

They can split up into expensive hotel rooms, which many will avoid.

They can stay in an illegal STR within the city, where Beverly Hills collects no tax revenue and takes on enforcement risk.

Or they can book an STR home just outside the city limits, where the City loses both TOT revenue and local business spending.

Many will choose the latter, meaning the city’s ban could inadvertently drive visitor dollars to neighboring jurisdictions.

To be clear, the core hotel market (business travelers on expense accounts, couples seeking a luxury getaway, etc.) will continue to patronize hotels in the city.

STRs are not replacing the Beverly Wilshire.

What STRs do is supplement and diversify the accommodation offerings for those visitors whose needs aren’t met by traditional hotels.

In economic terms, they enlarge the pie of total visitors rather than simply slice into the hotel’s share.

Banning STRs entirely is akin to the hotel industry banning all cruise ships because cruises provide an alternative form of travel lodging.

Yes, if the City banned cruise ships, some would-be cruise-goers might stay in hotels instead, but many would simply choose a different vacation destination or experience.

Likewise, banning STRs won’t fill all those people into hotel beds; it will cause many to either not come or stay elsewhere nearby.

The City should consider this dynamic, especially with major events on the horizon like the 2026 FIFA World Cup and the 2028 Olympic Games in Los Angeles.

Those events will draw an enormous influx of visitors to the region.

Wouldn't Beverly Hills prefer to have as many of these visitors as possible stay within the City, paying TOT and supporting local businesses?
STRs, if allowed and taxed, would expand the City’s capacity to host visitors during these surges and help ensure that Beverly Hills captures the associated tourism spending.

A real-world example of how STR regulation can benefit a city: Manhattan Beach, not far away, initially allowed STRs but then banned them outright in residential zones around 2015.

That ban was challenged in court because, unlike Beverly Hills, Manhattan Beach has a Coastal Zone where the Coastal Commission must approve such restrictions.

Manhattan Beach lost that case on appeal, and the ban was ultimately deemed unenforceable within the Coastal Zone.
10 As the result, the City had to stop enforcing it there and instead implement a regulated STR program for that area.

Hermosa Beach, now facing a similar legal challenge, recently lost a request for an injunction and is proceeding to trial.

The outcome? Manhattan Beach now collects approximately $1 million annually in TOT from short-term rentals.

Manhattan Beach also implemented sensible regulations, such as limiting STRs to certain zones and capping their density to preserve neighborhood character.

As a result, the earlier complaints that had accompanied unregulated STRs largely subsided once these rules took effect.

In other words, reasonable regulation turned a situation that was formerly underground and untaxed into a revenue generator for the city.

Beverly Hills, by regulating instead of banning, could likewise capture revenue that is currently being lost.

Housing Stock and Rental Availability
Councilmember Lester Friedman tied the ban to larger issues like California’s housing shortage, saying “it’s really important that we create the stock of availability for people to either… get into a home or get into an apartment.”
He added that the state has been pressuring cities about the lack of rental units and saw the STR ban as “part of that puzzle” of freeing up living spaces.

I appreciate the concern for housing affordability.

However, I believe from experience banning STRs will have little to no positive effect on the availability of long-term housing in Beverly Hills, and could even be counterproductive in some ways.

Beverly Hills is an unusual, high-end market.

Many STR listings here are in single-family homes, second homes that are hardly used, guest houses, ADUs, or spare bedrooms that owners occasionally rent out.

Crucially, those properties are often not part of the long-term rental market to begin with.

Some are second homes used by their owners for only a few days a year, sitting vacant the rest of the time.

Others are owner-occupied homes where an extra room is sometimes offered to travelers, but the owner would never rent that room to a long-term roommate or full-time tenant.

In yet other cases, an owner might temporarily move out and rent their primary home short-term, as I did when facing financial hardship, but they intend to return and therefore would not lease it out for a full year or more.

In all these scenarios, an STR ban doesn’t suddenly create a new unit of housing for a local worker or family, it simply means that space will go unused.

The home will remain empty when the owner is away, or the guest house will remain available only for the owner’s occasional use, etc.

Meanwhile, the homeowner loses the income that the STR was providing, which may have been helping them pay their property taxes or mortgage. 11 Broad statistics about STR impacts are often cited without context.

For example, a study by McGill University (commissioned by the hotel-funded Better Neighbors LA) asserted that prior to the pandemic about 7,300 housing units were removed from Los Angeles’s long-term rental market due to STR activity.

But that figure covers the entire City of Los Angeles, which has millions of housing units and a very different housing profile than Beverly Hills.

In L.A., many of those 7,300 units were likely apartment units in places like Hollywood or Venice that were being used illegally as full-time vacation rentals, including some rentstabilized apartments taken away from tenants.

Those may be legitimate concerns in Los Angeles.

Beverly Hills, by contrast, has far fewer rental apartments, and your Rent Stabilization Ordinance already protects against using those units for short-term rentals.

You don’t have big blocks of rent-controlled apartments being converted to Airbnbs, that would already violate existing law.

So the situations driving that 7,300-unit number largely don’t apply in your city.

In Beverly Hills, the number of STRs at any given time is relatively modest (AirDNA analytics tracked roughly 854 active STR listings in Beverly Hills over the past year, and many of those are likely not entire housing units but rooms or guest houses).

And again, a good chunk of those 854 “listings” are in properties that would otherwise be vacant or underutilized.

The net impact on your long-term rental supply is probably minimal.

Frankly, there are many homes in Beverly Hills that sit empty as second homes or investments, which is a broader issue beyond the scope of STRs.

If anything, allowing those owners to rent their properties out occasionally and legally increases the effective supply of housing, even if it is short-term, and brings visitors and revenue into the city without displacing anyone.

It’s also worth noting that Beverly Hills has already struggled with state mandates for housing, unrelated to STRs.

The city has been resistant to high-density development, as noted in news reports about state officials criticizing your progress on new housing.

Your lack of affordable housing will not be solved by an STR ban; it needs comprehensive planning and development of appropriate housing units.

Banning STRs is at best a distraction from real housing solutions, and at worst it could harm some residents financially while doing nothing to make rents in Beverly Hills more affordable.

In short, the STR ban will not meaningfully improve long-term housing availability or affordability in Beverly Hills.

What it will do is punish homeowners who were using STR income to get by, and reduce the number of visitors (and their dollars) coming into your city.

I urge you not to pin hopes on a ban as a housing solution, it isn’t one.

Instead, if housing is the concern, focus on housing policies directly (zoning, development 12 incentives, etc.), and manage STRs through regulations that prevent abuse but still allow this limited, productive use of properties.

The Influence of Outside Advocacy (BNLA)
I want to address the role of Better Neighbors LA (BNLA), since two of its representatives spoke at the meeting and provided commissioned research and policy recommendations aligned with hotel industry interests.

BNLA representatives appear regularly at City Council and Coastal Commission meetings across California, promoting a consistent message in support of STR bans. Their presence, repeated talking points, and funding sources suggest a coordinated campaign aligned closely with hotel union interests.

While BNLA bills itself as “a coalition of Southern California hosts, tenants, housing activists, hotel workers, and community members,” it is heavily funded by the hotel industry and their unions and advocates strongly for eliminating STR competition.

The research and talking points BNLA provided to you, such as the McGill study mentioned earlier, were presented as definitive but were not impartial.

They were produced by a group with a clear policy agenda and appear to have been commissioned to support a predetermined narrative.

Yet this data was treated by the City as objective fact and used to justify a complete STR ban, with the City now appearing to adopt many of their recommended policies.

Its core mission is to lobby for full crackdowns or bans on STRs, which is no coincidence, since that would eliminate competition for hotels.

Unsurprisingly, their materials focus on extreme scenarios mostly drawn from cities where STRs operated without regulations.

If you only look at cities that had no STR rules (the “Wild West” cases), of course you’ll find horror stories: party mansions, investors buying up whole apartment buildings for Airbnb, and other abuses.

But Beverly Hills is not in that situation, and more importantly, you have the ability to craft reasonable regulations to avoid those scenarios.

Unregulated STRs can indeed cause havoc. It is similar to removing all liquor laws and watching bars turn into public nuisances.

But cities do not have to choose between chaos and prohibition. Regulation is possible.

I was troubled to hear how much the BNLA perspective dominated the discussion.

There is no equally organized group on the other side of this issue.

Ordinary STR hosts are not united in a single lobbying group, and Airbnb as a company tends to stay behind the scenes or offer generic statements.

That is why you heard many speakers echo BNLA’s arguments, and only a few individual residents (like Ms. Blum) speaking up for STR allowances.

The playing field at that meeting was skewed.

I truly appreciate that the Council listened attentively to those who spoke.

You showed great responsiveness.

But I ask that you also consider the voices that were not in the room: the responsible STR hosts who didn’t know about the meeting, the homeowners quietly relying on STR income, 13 the visitors who would stay here if they could find a legal STR. Their perspective matters too.

Enforcement: Regulation vs. “Whack-a-Mole” Bans
An attorney who spoke on July 1 recommended some very harsh enforcement measures for illegal STRs, including massive fines and even criminal charges (jail time).

While the desire to make enforcement meaningful is understandable, the City must be careful.

Imagine the optics of a six-month jail sentence for a disabled veteran renting out his spare room. That is not something Beverly Hills should be aiming for.

Heavy-handed enforcement might deter some violators, but it could also punish people who turned to STRs out of financial desperation.

It’s also important to recognize that enforcement is getting more challenging under a banonly approach.

In the past, the City could hire companies like Host Compliance to scan Airbnb and VRBO listings for signs of violations. For example, if a listing showed a minimum stay of less than 30 days, that would indicate a violation of the City’s previous rules.

However, both Airbnb and VRBO recently removed the automatic display of a listing’s minimum-night requirement.

Now, an STR host can advertise without clearly stating the minimum stay.

The only way to catch a violation may be to attempt a test booking for a short period.

This is a resource-intensive strategy that requires city staff or contractors to go through the full reservation process, including paying a deposit up front, to see if the host accepts the booking.

I personally know illegal STR operators in Hermosa Beach who have stayed under the enforcement radar since the rental sites removed the automatic minimum stay display.

As Hermosa Beach’s City Attorney eloquently put it in March 2025, trying to enforce a total ban is like playing “Whack-a-Mole” — as soon as you knock one illegal listing down, another pops up elsewhere.

Hermosa Beach has been issuing fines and even filing lawsuits, yet as of this month, hundreds of STRs are still operating illegally.

An outright ban tends to drive the practice underground, making it even harder to monitor or control.

And again, an underground STR pays no TOT.

By contrast, a regulated framework brings hosts into the light.

If Beverly Hills creates a legal path for at least some STRs with strict conditions, many hosts will gladly register and comply.

The City will then know exactly who they are and where they operate.

Enforcement can focus on the truly rogue actors.

Also, the City can require STR platforms to de-list any property not included in Beverly Hills permit STR registry, something both Los Angeles and Santa Monica have implemented 14 successfully.

Because those cities allow legal STRs, Airbnb provides this enforcement mechanism directly through its platform.

In this model, Airbnb itself helps filter out illegal listings.

But they only cooperate where legal operation is possible.

The more viable the legal pathway, the more incentive platforms like Airbnb have to assist with enforcement.

In short, regulation brings folks into compliance; prohibition incentivizes evasion.

I would much rather have 50 legal, responsible STRs that the City can track and tax than 200 illegal ones playing hide and seek with code enforcement and avoiding any contribution to the City.

I want to emphasize again: Beverly Hills doesn’t have to choose between “party house chaos” and a total ban.

There is a sensible middle ground.

Dozens of cities have implemented balanced STR regulations that protect neighbors and housing without outlawing STRs completely.

You can limit the number of STR permits, restrict STRs to certain zones or property types, enforce quiet hours and occupancy limits, prohibit any corporate-run “mini hotels”, etc.

Yes, these regulations require effort to enforce, but so would a ban, which offers far less benefit in return.

Given Beverly Hills’ resources and thoughtful governance, I am confident you can develop an ordinance that allows responsible home-sharing while swiftly dealing with bad actors.

Potential Unintended Consequences of a Total Ban
Before closing, I’d like to outline a few unintended consequences that a blanket ban on STRs could have.

These are outcomes that I’m sure the Council does not desire, but they are very real risks:
• Economic Hardship for Some Residents:

A number of Beverly Hills homeowners have invested significant money and labor to prepare their homes for STR use.

This includes furnishing spaces, providing linens and towels, and purchasing durable guest-use items such as irons, hair dryers, luggage racks, brooms, and mops.

These are not disposable supplies but fixed assets intended specifically for guest stays.

If all STRs are banned, those investments are lost and those income streams vanish overnight.

A host has little use for an extra iron or hairdryer once the property is no longer rentable short-term.
15 For someone on the financial edge, this could mean foreclosure or being forced to sell their home.

Even if such cases are now few in Beverly Hills, I hate to think of even one family losing their home because a city policy took away their ability to make ends meet. • Lost Tourism Dollars:

Beverly Hills is internationally recognized as a premier destination, with a longstanding reputation for hospitality and service.

Banning STRs will reduce the accommodation options in our city, likely driving some visitors to stay in other nearby areas.

The City could lose out on significant TOT revenue. Currently, you collect almost nothing from the STR activity that does occur, but that revenue could be captured through proper regulation.

Beyond TOT, when visitors stay elsewhere, they also spend their money elsewhere:
dining, shopping and more.

Especially with the Olympics and World Cup fast approaching, it seems prudent to welcome more visitors in a controlled way rather than discourage them from staying in the city.

Every visitor who stays in an STR could be contributing TOT and supporting local businesses.

If they stay in West Hollywood instead, the City gets none of those benefits. • Increased Strain on Hotels & Higher Prices:

Also remember: STRs often serve as a “pressure release valve” for lodging demand.

Without them, hotel markets can overheat during peak seasons or special events.

We’ve seen this play out in places like Las Vegas, where explosive demand has pushed average daily hotel rates up by nearly 70% since 2015, with nightly costs rising from $124 to $209 in 2024, plus hefty resort fees and surcharges that led to public backlash and a 14% drop in occupancy year over year.

For Beverly Hills, this suggests that banning STRs entirely could spike hotel prices, especially for mid‑range families or local visitors, and fuel a narrative that only millionaires can afford a stay here.

A modest supply of well-regulated STRs helps keep lodging options accessible and pricing competitive, which in turn benefits hotel partners, local residents, and the City’s TOT revenue.

Beverly Hills has never been a budget destination, but the perception that only millionaires can stay overnight could damage the broader appeal of Beverly Hills to visitors and to family members of residents alike.

A few legal STRs providing alternative accommodations could help keep overall prices and availability in a healthier balance.
• Impact on Local Families and Events:

Sometimes STRs serve our own community’s needs.

For example, a Beverly Hills resident hosting a family reunion or a wedding might currently rent a nearby STR so that relatives can stay together close by.

I’ve personally hosted many guests who were visiting friends and relatives, and several were referred to me by my neighbors to stay at my place. 16 If STRs are banned, those visiting relatives either crowd into the host’s house, pay for multiple hotel rooms, or stay far away.

None of those outcomes is ideal for families.

Banning STRs removes that flexibility for your residents to accommodate their loved ones during special occasions.
• Empty Homes & Neighborhood Quietness:

Ironically, a total ban might lead to more dark, empty houses in residential areas.

Beverly Hills has many homes that are second residences for people who primarily live elsewhere.

Right now, some of those owners allow occasional STR use, which means the house has lights on, a gardener or housekeeper coming by, and generally looks lived-in because at times it actually is.

If STRs are banned, those houses will just sit empty for months on end until the owner visits.

An empty house isn’t great for a neighborhood, it can become a target for break-ins, or just create a dead spot on the street.

Occasional STR guests actually keep the house active and well-maintained. In fact, owners who operate STRs often keep their property in top condition to earn good reviews.

In other words, responsible STRs can activate otherwise underused housing stock, whereas a ban might inadvertently create more zombie homes that sit unoccupied. • Enforcement Burden and Legal Risks:

Cracking down on every STR will require a significant and ongoing effort.

This includes monitoring websites, conducting in-person surveillance, responding to anonymous tips, issuing citations, and pursuing legal action against noncompliant operators.

The question is whether the payoff justifies the cost.

The City might end up spending tens of thousands of dollars on staff or contractor hours to net a handful of fines, all while hundreds of STRs continue to operate undetected.

Meanwhile, if the City comes down too hard, such as by jailing a homeowner or imposing exorbitant fines, it could face legal challenges.

In Texas, a different legal context from California, the City of Dallas adopted ordinances in mid‑2023 that would have effectively banned most short‑term rentals in single‑family residential zones.

Those measures were blocked by a Dallas County judge on the grounds that they violated property rights and the Texas appeals court recently upheld that injunction, meaning Dallas cannot enforce its STR ban while litigation continues.

This suggests that outright bans, without a clear legal path or grandfathering, may expose jurisdictions to court challenges, even when the rationale is neighborhood preservation.

This underscores the importance of crafting regulations carefully to avoid takings claims or procedural overreach.
17 Summary
In summary, I urge the City Council to reconsider adopting a blanket STR ban and instead implement a set of reasonable STR regulations.

Based on my experience and the evidence:
• STRs are not inherently incompatible with the community.

It is unregulated STRs that cause most problems.

Beverly Hills can allow a limited, well-regulated amount of short-term renting and prevent the nightmare scenarios through careful rules and enforcement. • Beverly Hills can protect neighborhood character without a ban.

Measures like owner occupancy requirements, limits on the number of STRs per block, strict noise ordinances, occupancy caps, and swift penalties/permit revocation for violations can all ensure that STRs do not disrupt neighbors.

Many cities have shown that once such rules are in place, complaints plummet. • There is economic benefit to keeping STRs legal (under controls).

The City can capture TOT from legal STR stays, which is currently being lost entirely.

Local businesses also benefit from visitors who might not otherwise come.

What the hotel industry may lose from a subset of travelers could become a gain for the City if STRs are brought into a taxable and regulated framework. • Housing impacts can be mitigated and are likely minor in Beverly Hills.

We should acknowledge that Beverly Hills’ STRs are rarely units that would have been rented long-term to local residents.

By carving out sensible rules, you can ensure you are not significantly affecting the long-term rental stock.

A ban, by itself, will not suddenly make homes affordable or available in Beverly Hills.

Those issues need larger solutions.
• The ban approach has downsides.

It puts otherwise law-abiding residents in an adversarial position with the City by pushing them to operate in secret.

It also throws away a source of revenue and creates the risk of unintended consequences like those described above.

Regulation, on the other hand, allows for a collaborative approach.

Residents gain a legal outlet to earn income with clear expectations set by the City.

Neighbors receive protections and a responsive City if problems arise, and the City gains both revenue and oversight.

I am not a paid consultant, nor a professor funded to publish studies that support a predetermined narrative.

I’m just a private individual who lived in a sea of STRs for ten years and then operated one myself for six years, giving me a solid perspective on both sides of the issue.

My understanding comes from real-life experience rather than theory, and my only interest is in seeing sensible policy that balances the needs of residents, visitors, and businesses. 18 I genuinely fear that a complete STR ban in Beverly Hills will do more harm than good, solving little while hurting many.

Thank you for considering a viewpoint that was not strongly represented at the July 1 meeting.

I trust the City Council will also give weight to the voices not in the room and work toward a policy that addresses concerns without eliminating a practice that, when done responsibly, truly can work for everyone.

As someone on full disability, attending public meetings is difficult.

If invited or if future discussions take place, I will make every effort to participate in person.

Otherwise, please accept this letter as my full public comment on the matter.

Thank you for your time and consideration.

Sincerely,
Jim Holtz
Hermosa Beach, CA
2601 Ocean Park Blvd. • Suite 205 • Santa Monica, CA 90405 (310) 314-6433 • www.angellaw.com • [email protected] August 5, 2025
Honorable Mayor Nazarian and City Councilmembers
Beverly Hills City Council
455 N. Rexford Dr.

Beverly Hills, CA 90210
Via email to [email protected], [email protected], [email protected], [email protected], [email protected], and [email protected]
RE: Legality of Proposed Rental Regulations
Honorable Mayor Nazarian, Vice Mayor Mirisch, and City Councilmembers:

Our office submits this letter on behalf of interested stakeholders in the City of Beverly Hills (City). We write to share our strenuous legal objections to the ordinance amending the City’s existing short-term rental (STR) regulations to further restrict and prohibit both STRs and so-called “intermediate-term rentals” (ITR) (the Draft Ordinance).1 The Draft Ordinance is patently unconstitutional and unlawful. It infringes on constitutionally protected property rights and significantly impedes individuals’ rights to travel, to work, and to reside within the City. The Draft Ordinance represents a divisive and misguided regulatory approach, ignoring its severe implications on constitutional rights, housing opportunity and diversity, and community economic and environmental health. Rather than embodying legitimate governance, it exemplifies a pretextual overreach without precedent, targeting specific property owners and renters, at the behest of economic competitors, under the guise of regulating a use. 1 STRs and ITRs will generally be referred to as “STRs/ITRs” in this letter, since the Draft Ordinance proposes to ban all leases less than one year encompassing both traditional STRs (30 days or less) and ITRs (flexible term leases less than 1 year -- e.g., one-moth month leases, six-month leases, etc.).

However, those proposed regulations uniquely affecting ITRs will be referred to as “ITRs.” Beverly Hills City Council
August 5, 2025

The Draft Ordinance unlawfully and impermissibly discriminates against renters, nonpermanent resident travelers, visiting families, hospital employees, teachers, construction workers, and other essential personnel who depend on flexible housing arrangements to live and work in Beverly Hills. Furthermore, it disproportionately impacts vulnerable populations and economically disadvantaged individuals, effectively excluding those unable to afford first and last months' rent and a security deposit from living within City borders.

The Draft Ordinance Violates Numerous Constitutional Rights The Draft Ordinance infringes upon numerous constitutional rights of both property owners and renters. The City has not provided any substantiated justification or rational basis for its approach, nor has it met the heightened level of scrutiny required for municipal action that impedes fundamental rights. Specifically:

The Draft Ordinance Infringes on Vested Rights and Due Process.

The Draft Ordinance violates property owner's vested rights by prohibiting all STRs/ITRs, including those that have been operating legally for years. This abrupt abrogation of an existing lawful use contravenes established constitutional doctrine (see Hansen Brothers Enterprises, Inc. v. Board of Supervisors (1996) 12 Cal.4th 533, 540, fn. 1; Hill v. Manhattan Beach (1971) 6 Cal.3d 279, 285-286) and the Beverly Hills Municipal Code (BHMC), which protects lawful nonconforming uses. (BHMC, § 10-3- 4101 [“nonconforming [land] uses may be continued, without alteration or expansion, although such use no longer conforms to the provisions of” the zoning code].) The Draft Ordinance further violates property owners' due process rights under both the California and U.S. Constitutions by terminating lawful nonconforming uses and depriving property owners of their property without due process of law. It infringes upon property rights, including the right to lease and include others on one's property, as well as rights to privacy and freedom of travel. Given the lack of any evidence supporting the purported prohibitions or any legitimate governmental interests, the Draft Ordinance fails to meet the rational basis test, let alone the heightened scrutiny required when legislation infringes upon fundamental rights (as is happening here). (Cmty. Res. for Just., Inc. v. City of Manchester (N.H. 2007) 917 A.2d 707, 717.) Property Owners Will Have Takings Claims if the Draft Ordinance is Adopted.

The Draft Ordinance constitutes a per se taking under both the California and U.S.

Constitutions by appropriating fundamental property rights, including the right to lease and include others on one's property. (Lingle v. Chevron U.S.A., Inc. (2005) 544 U.S. 528, 537; Terrace v. Thompson (1923) 263 U.S. 197, 215; Union Carbide Corp. v.

Alexander (Tenn. 1984) 679 S.W.2d 938, 940.) When the government “appropriates for the enjoyment of third parties” “a fundamental element of the [owners’] property right” (Cedar Point Nursery v. Hassid (2021) 594 U.S. 139, 147) or “otherwise interfere[s] with Beverly Hills City Council
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[such fundamental] right[s],” “[t]hat sort of intrusion on property rights is a per se taking” that automatically “trigger[s]” the “right to compensation.” (Sheetz v. County of El Dorado (2025) 601 U.S. 267, 274.) The Draft Ordinance empowers the City to decide the appropriate length of time that an owner may open their property to a guest and drastically curtails the owner’s right to rent the property, as well as the owner’s right to include others on it. By appropriating these essential elements of property ownership the City effects a per se taking of each property owner’s rights, requiring the City to provide property owners with just compensation. (Cedar Point Nursery, 594 U.S. at 148- 150; Sheetz, 601 U.S. at 274.)
The Draft Ordinance also effects a regulatory taking under the California and U.S.

Constitutions because the economic impacts of the ban would be severe for property owners, who have reasonable, investment-backed expectations in their ability to continue operating STRs/ITRs. (See Penn Central Transp. Co. v. New York City (1978) 438 U.S. 104, 124.)
The Draft Ordinance Violates Equal Protection.

The Draft Ordinance violates property owners’ and renters’ equal protection rights under the California and U.S. Constitutions by discriminating between similarly situated owners and tenants seeking to rent, depending on the length of the lease term. The Draft Ordinance disproportionately and inequitably impacts renters from economically disadvantaged and underrepresented populations, who have suffered from substantial and increasing home inaccessibility and wealth disparities. The Draft Ordinance fails to pass heightened scrutiny required for classifications that impinge a fundamental right. (See Nunez by Nunez v. City of San Diego (9th Cir. 1997) 114 F.3d 935, 944, 946; Halet v. Wend Inv. Co. (9th Cir. 1982) 672 F.2d 1305, 1311; Coalition Advocating Legal Housing Options v. City of Santa Monica (2001) 88 Cal. App.4th 451, 462.) The Draft Ordinance Constitutes a Restraint on Alienation.

The Draft Ordinance imposes unreasonable restrictions on property owners' ability to rent out their properties and tenants' ability to sublet. California law generally prohibits such restrictions due to the negative impact they have on a property's value and utility in the market. (See Godoy v. Linzner (2024) 106 Cal.App.5th 765, 776; Dawn Investment Co. v. Superior Court (1982) 30 Cal.3d 695, 703-704; Wellenkamp v. Bank of America (1978) 21 Cal.3d 943, 953.) The ban on STRs/ITRs fails to appropriately balance the claimed necessity of the restriction with the extent of its limitation. As a result, it effects an unlawful restraint on the alienation of property.

The Draft Ordinance Interferes with the Right to Contract.

The immediate prohibition of STRs/ITRs in the City interferes with property owners' constitutional right to contract, a right protected under both the California and U.S.

Constitutions. It substantially impairs existing contractual relationships by invalidating Beverly Hills City Council
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agreements that property owners have made to rent their properties on a short- and intermediate-term basis in the coming months. (See Alameda County Deputy Sheriff’s Assn. v. Alameda County Employees' Retirement Assn. (2020) 9 Cal.5th 1032, 1075.) The Draft Ordinance Infringes on Individuals’ Right to Privacy.

The Draft Ordinance infringes on property owners’ and renters’ inalienable rights to privacy as protected by the California Constitution, which includes the right to privacy in one’s home. (See City of Santa Barbara v. Adamson (1980) 27 Cal. 3d 123, 130.) By prohibiting rentals less than one year, the ordinance severely restricts homeowners’ and renters’ ability to choose who can stay in their homes. That violates their privacy rights. (Coalition Advocating Legal Housing Options, supra, 88 Cal.App.4th at p. 459.) The City provided no substantial justification for this infringement.

The Draft Ordinance Violates the Dormant Commerce Clause.

The Draft Ordinance violates the Dormant Commerce Clause of the U.S. Constitution by, among other things, disproportionately impacting individuals seeking flexible-term housing, thereby favoring local long-term residents and impeding non-residents' participation in the City's rental and job market. (United Haulers Ass’n, Inc. v. OneidaHerkimer Solid Waste Mgmt. Auth. (2007) 550 U.S. 330, 338.) This undue burden on interstate commerce is not justified, as the City has not demonstrated that the Draft Ordinance even-handedly effectuates a legitimate local public interest, nor shown any evidence that STRs/ITRs contribute to nuisance or housing problems, as discussed in more detail below. (Pike v. Bruce Church, Inc. (1970) 397 U.S. 137, 142.) Adoption of the Draft Ordinance Would be Arbitrary and Capricious The City justifies its unprecedented approach to restricting rental housing based on unsupported allegations that STRs/ITRs impact housing affordability or cause nuisances. The City offers no meaningful support for these justifications.

First, the City fails to provide any evidence that STRs/ITRs affect housing affordability in the City -- the staff report uses flimsy language claiming STRs/ITRs “likely” affect the City’s long-term housing affordably and “may” exacerbate the affordable housing crisis in the greater Los Angeles area, providing no actual data to support these statements.

Empirical evidence supports the conclusion that STRs in fact support housing affordability by allowing homeowners to recoup some investment by renting their homes, and that the only solution to California’s housing crisis is to build more housing. (Dubetz et al, Staying Power: The Effects on Short-Term Rentals on California’s Tourism Economy and Housing Affordability, Milken Institute, p. 1 (2022); Betsey Stevenson, Banning Airbnb Won’t Solve the Housing Crisis, Bloomberg News (July 8, 2024).)
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The Draft Ordinance is also fundamentally inconsistent with the City’s General Plan policies aimed at providing diverse and affordable housing options, because it eliminates numerous flexible term lease options and reduces the diversity and affordability of housing. It further fails to consider the diverse housing needs of individuals such as students, teachers, medical professionals on rotation at UCLA, St.

John’s and Cedars-Sinai, families and individuals whose homes are under renovation, and victims of natural disasters such as the January 2025 wildfires, who rely on flexible lease terms to live in the City. The benefits of flexible-term leases are extensive, and the corresponding costs of eliminating such leases significant, yet none are discussed or assessed in the various staff reports to the Planning Commission and City Council. This glaring omission and overgeneralized, simplistic rationalization for banning all leases less than 12 months is highly problematic. It suggests the City has either not considered any of these benefits, or more callously, does not wish to provide flexible accommodations for the variety of individuals who rely on them.

With respect to alleged nuisance impacts, the only evidence in the record is aggregated case data from the City’s code enforcement over a 10-year period showing there have been a nominal number of cases related to STRs resulting in a compliance order or citation. (July 1 Staff Report, Attachment 6 - Nov. 14, 2024, Planning Commission Report, pp. 3-5.) Contrary to the City’s position, this data actually demonstrates that a complete ban on all STRs/ITRs in the City is unreasonable, and any “bad actor” issues could be addressed through straightforward enforcement of the City’s generally applicable nuisance laws. (See, e.g., BHMC §§ 6-1-404 [solid waste accumulation]; 5-1- 302 [loud or unruly gathering]; 1-3-103 [City authority to abate public nuisance, enforce].)
There is also no data to show that any complaints came from ITRs – the data is silent as to the length of the rental term that the complaints and citations arose from. In fact, the data is silent on the nature of the complaints and if the issues identified were even nuisance-type activity. This failure is coupled with the fact that the City has not collected evidence to understand how many STRs/ITRs are operating in the City and what the impacts would be of banning them on the City’s economy and the environment.

Given the lack of meaningful evidentiary support that STRs/ITRs contribute to the City’s housing affordability challenges or nuisance activity in the City, and the failure of the City to evaluate the potential economic and environmental impacts of its unprecedented restrictions on property rental, adopting the Draft Ordinance will be arbitrary and capricious. (See Strumsky v. San Diego County Employees Retirement Assn. (1994) 11 Cal. 3d 28, 34; see also Avenida San Juan Partnership v. City of San Clemente (2011) 201 Cal.App.4th 1256, 1268.)
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The Draft Ordinance Would Have Significant Environmental Impacts2 Under the California Environmental Quality Act (CEQA), a local agency must prepare an Environmental Impact Report whenever a project “may have a significant effect on the environment.” (Pub. Resources Code, § 21151.)
Ramboll found that the Draft Ordinance, if approved, may increase emissions and noise to such degree as to have the potential to cause significant impacts on the environment, cognizable under CEQA. As explained in the Ramboll Analysis, these impacts also have health-related effects that should be evaluated further. Indeed, CEQA requires the City to evaluate whether “[t]he environmental effects of a project will cause substantial adverse effects on human beings, either directly or indirectly.” (Pub. Resources Code, § 21083, subd. (b)(3), (d); CEQA Guidelines, § 15065, subd. (a) (4).) CEQA mandates a finding of significant impact when substantial adverse effects on human beings are caused by a project. (Id.) These effects must be fully disclosed and evaluated in-depth in an EIR (Id.; see also Pub. Resources Code, §§ 21068, 21100), and feasible measures to avoid or at least substantially lessen them must be discussed. (Id., §§ 21002, 21002.1, 21081.) Adverse effects on human health and safety, unquestionably, are “adverse effects on human beings” within the meaning of CEQA. (California Building Industry Assn. v. Bay Area Air Quality Management Dist. (2015) 62 Cal.4th 369, 386.)
The City’s finding that the Draft Ordinance is exempt from CEQA fails. It is not exempt under the commonsense exemption (July 1 Staff Report, p. 9; CEQA Guidelines, § 15061, subd. (b)(3)) because it cannot be “seen with certainty” that the Draft Ordinance has no potential to cause a significant environmental effect -- as discussed below, significant impacts are reasonably foreseeable. (See Davidon Homes v. City of San Jose (1997) 54 Cal.App.4th 106, 117 [“the agency’s exemption determination must be supported by evidence in the record demonstrating that the agency considered possible environmental impacts in reaching its decision”].)3
2 Please refer to the Environmental Analysis of Short-Term Rental Regulation in Beverly Hills, prepared by Ramboll Americas Engineering Solutions, Inc., submitted along with this comment letter (Ramboll Analysis).

3 The Draft Ordinance also does not qualify for the Class 5 categorical exemption for "Minor Alterations in Land Use Limitations." (July 1 Staff Report, p. 9; CEQA Guidelines, § 15305.) This exemption is intended for individual changes of use, such as lot line adjustments, variances, minor encroachment permits, and reversion to acreage, rather than municipal ordinances that establish new, generally applicable regulatory policies applicable throughout a city’s entire incorporated territory. (See CEQA Guidelines, § 15305.) Even if the Draft Ordinance did fit into the Class 5 exemption—which it does not—the unusual circumstances exception under CEQA Guidelines section 15300.2, subdivision (c) would apply. The Draft Ordinance is distinguishable from projects in the exempt class due to its geographic scale and scope.

Furthermore, there is a reasonable possibility of significant environmental effects arising from these unusual circumstances, as eliminating many STRs/ITRs from the City may lead to substantial adverse direct and indirect environmental impacts.

Beverly Hills City Council
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Removing all existing STRs/ITRs from the City will almost certainly change traffic patterns. This shifting of traffic from within the City and its job centers to other locations in the Southland may have significant environmental impacts, including increased vehicle emissions from people traveling further distances to their places of employment and residence. This may result in adverse air quality impacts to residents of Beverly Hills and potential traffic impacts at new locations.

Courts have concluded that such potential impacts are sufficient to require an initial study. For example, in Union of Medical Marijuana Patients, Inc. v. City of San Diego (2019) 7 Cal.5th 1171, 1198, the California Supreme Court held that San Diego’s medical marijuana ordinance was a CEQA project because it was capable of causing indirect physical changes in the environment, including changed traffic patterns. The court explained that “restrictions on the siting of dispensaries would require thousands of patients to drive across the City to obtain medical marijuana.” (Id. at p. 1182.) Potential changes to traffic and circulation were enough to require CEQA review. (Id. at 1200-1201.) The rule is indeed that a local ordinance must be considered a “project” subject to environmental review under CEQA, “if, by its general nature, the activity is capable of causing a direct or reasonably foreseeable indirect physical change in the environment. (Id. at p. 1197.) This determination is made without considering whether, under the specific circumstances in which the proposed activity will be carried out, these potential effects will actually occur. (Ibid., italics added.) Consistent with this standard, a ‘reasonably foreseeable’ indirect physical change is one that the activity is capable, at least in theory, of causing. (Guidelines, § 15064, subd. (d)(3).)” (Ibid., italics added.) Fullerton Joint Union High School District v. State Board of Education (1982) 32 Cal.3d 779 provides another example. There, the high court found a school district secession plan “will change bus routes and schedules, and affect traffic patterns. Although it is uncertain whether the total impact will be significant enough to require an environmental impact report, it is clear that it is sufficient to require at least an initial study to inquire into the need for such a report.” (Id. at 794.)
The New Private Right of Action Violates Equal Protection and Invites Frivolous, Discriminatory Litigation
The Draft Ordinance now includes a private right of action for those who collect and remit transient occupancy tax (TOT) to bring a civil action for alleged violations of the Draft Ordinance. This effectively transfers enforcement responsibility from the City to a class of competing businesses who would benefit from renters in the City being forced to stay in hotels or motels for extended periods of time. This transferring of enforcement authority to a specific class of private actors not only violates the equal protection rights of property owners and renters who are now potentially subject to targeting and selective enforcement, it will lead to increased litigation and community discord. Inviting these specific businesses to directly sue property owners and renters may also encourage frivolous lawsuits driven by personal or constitutionally suspect grievances.

There is simply no rational basis for the inclusion of such a private right of action.

Beverly Hills City Council
August 5, 2025

The New Private Right of Action Requires Planning Commission Consideration In addition, because the private right of action was added to the Draft Ordinance after the first reading, and it is a significant substantive change to what was previously considered, the Draft Ordinance must return to the Planning Commission for a report and recommendation before the City Council can approve it. (See Gov. Code, § 65857.) The City Cannot Legally Approve the Draft Ordinance
The Draft Ordinance not only bans a time-honored form of property use, it bans entire classes of persons from residing in or visiting Beverly Hills. It does so invidiously, under an unsupported guise of housing affordability and nuisance prevention. In actuality, STRs/ITRs provide access to housing (including affordable access) for many in the temporary workforce (traveling nurses, project-based employees or contract workers, construction workers, substitute teachers, retail workers during the holiday season, temporary administrative assistants, temporary travel nannies etc.), foster local tourism and economic vitality, and promote environmental sustainability. These benefits are not incidental -- they are central to the California dream and the liberty the California and U.S. Constitutions exist to protect. Beverly Hills does not have the right nor authority to take this dream and suppress this liberty.

Sincerely,
Frank P. Angel
1/17
Date: August 4, 2025
From: Sarah Manzano and
Brent Ferren
Ramboll
333 Bush St.,Suite 2500
San Francisco,CA 94104
USA
T+1 415 796 1950
https://ramboll.com

ENVIRONMENTAL ANALYSIS OF SHORT-TERM RENTAL

REGULATION IN BEVERLY HILLS, CA
Ramboll Americas Engineering Solutions, Inc. (Ramboll) evaluated potential air quality, greenhouse gas (GHG), energy and noise environmental impacts of a potential ban on short-term rentals (STR) in Beverly Hills, California for Airbnb.

As discussed throughout this memo, Ramboll found that the ban of STRs in Beverly Hills has the potential to increase emissions and noise, creating the potential for environmental and health-related impacts that should be evaluated further. The increase in emissions and noise have the potential to cause a significant impact in relation to California Environmental Quality Act (CEQA) and the life and well-being of the residents of Beverly Hills. 1 Overview
We understand that the current STR restrictions were adopted into City code in 2014 and limit single-family rental homes to two or less stays per year with less than 6 months per stay and renting multi-family STRs for less than 30 days is prohibited. This year, the City of Beverly Hills is proposing a complete ban on rentals of under 12 months for both single-family and multi-family properties.

As a result of the proposed STR ban, individuals would be unable to enjoy the benefits of STRs, which will increase demand for local hotels as the only option for short term stays within the City of Beverly Hills. As a result, individuals will be forced to travel greater distances to other commercial centers in the region to find available STRs and available/affordable hotels, introducing additional vehicle miles traveled (VMT). In particular, increased travel to and from hotels and STRs in the region because of the unavailability of STRs in Beverly Hills could increase emissions relative to South Coast Air Quality Management District (SCAQMD) thresholds for criteria air pollutants (CAPs), with the potential to cause shortterm and long-term health impacts to sensitive receptors, exceedances of applicable air quality standards, and inconsistencies with applicable air quality and climate plans, all of which create a fair argument of environmental impacts that need to be studied further under CEQA. The ban of STRs will also likely result in increased traffic congestion and noise impacts that require further study under CEQA.1,2
2 Health Impacts from Criteria Pollutants and Greenhouse Gases
Criteria air pollutants (CAPs) are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state 1 Airbtics reports 854 active short-term Airbnb rentals in Beverly Hills, which is referenced throughout this analysis. However, conclusions herein are largely based on comparative impacts to the elimination of short-term rentals and are not dependent on the actual number of short-term rentals in Beverly Hills today.
2 Airbtics 2025. Beverly Hills. Available at: https://app.airbtics.com/airbnb-data/UnitedStates/CA/Beverly%20Hills “P
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standards have been set, with an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive people from illness or discomfort. Pollutants of concern include ozone (O3), nitrogen oxides (NOx), carbon monoxide (CO), sulfur oxides (SOx), particulate matter less than 10 microns in diameter (PM10), and particulate matter less than 2.5 microns in diameter (PM2.5).

In addition to CAPs, GHGs, which include but are not limited to carbon dioxide (CO₂), nitrous oxide (N₂O) and methane (CH₄), are also of environmental concern due to their role in contributing to climate change. While not subject to ambient air quality standards, GHGs trap heat in the atmosphere and contribute to climate change, with far-reaching impacts on ecosystems, weather patterns, and human health.

The proposed STR ban has the potential to increase emissions of these pollutants. The background on their health impacts is discussed in the following paragraphs.

Ozone
O3 is a colorless gas that is formed in the atmosphere when volatile organic compounds (VOCs), sometimes referred to as reactive organic gases (ROG), and oxides of nitrogen (NOx) react in the presence of ultraviolet sunlight. O3 is not a primary pollutant; it is a secondary pollutant formed by complex interactions of two pollutants directly emitted into the atmosphere. The primary sources of VOCs and NOX, the precursors of O3, are automobile exhaust and industrial sources. Meteorology and terrain play major roles in O3 formation, and ideal conditions occur during summer and early autumn on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies. Short-term exposures (lasting for a few hours) to O3 at levels typically observed in Southern California can result in breathing pattern changes, reduction of breathing capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes.

Nitrogen Oxides
Most NO2, like O3, is not directly emitted into the atmosphere but is formed by an atmospheric chemical reaction between nitric oxide (NO) and atmospheric oxygen. NO and NO2 are collectively referred to as NOX and are major contributors to O3 formation. The primary sources of NO, the precursor to NO2, include automobile exhaust and industrial sources. High concentrations of NO2 can cause breathing difficulties and result in a brownish-red cast to the atmosphere, reducing visibility.

There is some indication of a relationship between NO2 and chronic pulmonary fibrosis, and some increase in bronchitis in children (2 and 3 years old) has also been observed at concentrations below

0.3 parts per million by volume (ppm).3,4
Carbon Monoxide
Carbon Monoxide (CO) is a colorless and odorless gas formed by the incomplete combustion of fossil fuels. CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial boilers, ships, aircraft, and trains. In urban areas, such as Beverly Hills, automobile exhaust accounts for the majority of CO emissions.5 CO is a non-reactive air pollutant that dissipates relatively quickly; therefore, ambient CO concentrations generally follow the spatial and temporal distributions of 3 Yoon et al. 2023. Nitrogen dioxide increases the risk of disease progression in idiopathic pulmonary fibrosis.

Respirology (Carlton, Vic.), 28(3), 254–261. Available at: https://doi.org/10.1111/resp.14373 4 Ghosh, et al. 2012. Ambient nitrogen oxides exposure and early childhood respiratory illnesses. Environment international, 39(1), 96-102. Available at: https://doi.org/10.1016/j.envint.2011.10.001 5 Transportation Research Board. 2002. The Congestion Mitigation and Air Quality Improvement Program:

Assessing 10 Years of Experience -- Special Report 264. Washington, DC: The National Academies Press. https://doi.org/10.17226/10350.
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vehicular traffic. CO concentrations are influenced by local meteorological conditions, primarily wind speed, topography, and atmospheric stability. CO from motor vehicle exhaust can become locally concentrated when surface-based temperature inversions are combined with calm atmospheric conditions, a typical situation at dusk in urban areas between November and February. These inversions occur when a layer of warm air sits atop cool air and are more frequent during the colder months of the year when the highest levels of CO typically occur. In terms of health, CO competes with oxygen, often replacing it in the blood, thus reducing the blood’s ability to transport oxygen to vital organs. The results of excess CO exposure can be dizziness, fatigue, and impairment of central nervous system functions.

Sulfur Oxides
Sulfur Dioxide (SO2) is a colorless, pungent gas formed primarily by the combustion of sulfurcontaining fossil fuels. The main sources of SO2 are coal and oil used in power plants and industries; as such, the highest levels of SO2 are generally found near large industrial complexes. In recent years, SO2 concentrations have been reduced by the increasingly stringent controls placed on stationary source emissions of SO2 and limits placed on the sulfur content of fuels. SO2 is an irritant gas that attacks the throat and lungs and can cause acute respiratory symptoms and diminished ventilator function in children. SO2 can also yellow plant leaves and erode iron and steel.

Particulate Matter
Particulate matter (PM) pollution consists of very small liquid and solid particles floating in the air, which can include smoke, soot, dust, salts, acids, and metals. Particulate matter can form when gases emitted from industries and motor vehicles undergo chemical reactions in the atmosphere. PM2.5 and PM10 represent fractions of particulate matter. Fine particulate matter, or PM2.5, is roughly 1/28 the diameter of a human hair. PM2.5 results from fuel combustion (e.g., motor vehicles, power generation, and industrial facilities), residential fireplaces, and woodstoves. In addition, PM2.5 can be formed in the atmosphere from gases such as sulfur oxides (SOX), NOX, and VOCs. Inhalable or coarse particulate matter, or PM10, is about one- seventh the thickness of a human hair. Major sources of PM10 include dust stirred up by vehicles traveling on roads; crushing or grinding operations; wood-burning stoves and fireplaces; dust from construction, landfills, and agriculture; wildfires and brush/waste burning; industrial sources; windblown dust from open lands; and atmospheric chemical and photochemical reactions.

PM2.5 and PM10 pose a greater health risk than larger-size particles. When inhaled, these tiny particles can penetrate the human respiratory system’s natural defenses and damage the respiratory tract.

PM2.5 and PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body’s ability to fight infections. Very small particles of substances such as lead, sulfates, and nitrates can cause lung damage directly or be absorbed into the bloodstream, causing damage elsewhere in the body. Additionally, these substances can transport absorbed gases, such as chlorides or ammonium, into the lungs, also causing injury. Whereas PM10 tends to collect in the upper portion of the respiratory system, PM2.5 is so tiny that it can penetrate deeper into the lungs and damage lung tissues. Suspended particulates also damage and discolor surfaces on which they settle, as well as produce haze and reduce regional visibility.

Greenhouse Gases
Greenhouse gases are gases that trap heat in the Earth’s atmosphere, contributing to the greenhouse effect and climate change. Unlike criteria air pollutants, GHGs are not directly associated with respiratory or toxic health effects at ambient levels but are significant due to their long-term impacts “P
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on global climate systems and human health through secondary effects such as increased heat waves, wildfires, and sea level rise.

The primary GHGs of concern include CO₂, CH₄, N₂O, hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF₆). Among these, CO₂ is the most prevalent, primarily emitted through the combustion of fossil fuels for transportation, electricity generation, and other industrial processes. CH₄ is released from landfills, agriculture (particularly from livestock), and oil and gas operations, while N₂O emissions are largely associated with agricultural activities and combustion.

Transportation is a major source of GHG emissions in Beverly Hills, contributing significantly to statewide CO₂ levels.6Increased VMT may contribute to a rise in regional GHG emissions. Although GHGs disperse globally, local increases in VMT contribute to the broader cumulative impacts of climate change.

While GHGs do not cause immediate local air quality issues in the way criteria pollutants do, their long-term effects include rising temperatures, changing precipitation patterns, reduced snowpack, and increased frequency and intensity of extreme weather events. These changes pose risks to both human and ecological health, infrastructure, and regional economic stability, especially in areas like Beverly Hills that are vulnerable to wildfire and extreme heat. 3 An STR Ban Will Increase Air Pollutant Emissions and Greenhouse Gas Emissions
Over the last 12 months, there were 854 active Airbnb listings in Beverly Hills, with an average occupancy rate of 63%.
7 These rentals play a key role in distributing visitors throughout the neighborhood, allowing them to stay close to their destinations of choice. Elimination of these Airbnb rentals and other short-term rentals in Beverly Hills may correspond with an increase in guests at Beverly Hills hotels, increasing trip lengths as visitors would have fewer lodging options close to their chosen destinations. In addition to choosing to stay at hotels, prospective guests may also choose to drive further to an STR in a different area with fewer restrictions, also leading to increased trip lengths.

In addition, the number of trips taken by guests to and from their site of accommodation would be higher for those staying in hotels than those choosing short-term rentals. According to the Institute of Transportation Engineers (ITE), the average weekday trip generation rate for Recreational Homes (ITE Land Use Code 260) is 3.55 trips per day, while the Hotel land use (ITE Land Use 310) generates an average of 7.99 trips per day. This discrepancy may be attributed to several factors, including the need for hotel guests to travel off-site for meals, shopping, and activities, as hotels often lack in-room full kitchens or in-room dining options. Additionally, hotels typically require a larger workforce, resulting in more employee commute trips. In contrast, STRs frequently serve longer-stay visitors who cook on-site, stay with families, or engage in fewer daily trips, thereby reducing traffic volumes in the surrounding area.

The increase in mobile emissions associated with staying at available STRs near Beverly Hills destinations compared to hotels or farther STRs is presented below in Table 1. Based on publicly available statistics on the current Airbnb listings in Beverly Hills, the average capacity per STR is 5.0 people and there are approximately 854 active Airbnb listings with an average occupancy rate of 6 City of Beverly Hills. 2025. Climate Action & Adaptation Plan (CAAP). Adopted April 22, 2025. 7 Airbtics 2025. Beverly Hills. Available at: https://app.airbtics.com/airbnb-data/UnitedStates/CA/Beverly%20Hills “P
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63%.
8 This results in a population of 2,690 people. As a result of the potential STR ban, 897 hotel rooms, assuming 3 people per room, would be required to accommodate a comparable number of visitors.

For this comparison, half of existing STR users are assumed to stay at hotels while the other half are assumed to stay at other STRs located farther from their destinations due to the reduction in availability in Beverly Hills.

The number of peak daily trips was estimated using the ITE trip rates for recreational homes and hotel land uses and the number of STRs and hotel rooms required to serve the same population.9,10 The number of daily miles traveled for the existing STRs was based on default assumptions from CalEEMod.
11 Visitors that would stay at STRs located farther away as a result of the STR ban are assumed to travel 5 miles longer since guests might have to stay in cities where the STR regulations are not as strict such as West Hollywood, Culver City, Santa Monica, or various neighborhoods in Los Angeles.12 Visitors that would stay at hotels as a result of the STR restrictions are assumed to travel the same distance as the existing STR.

Under the proposed ban, visitors staying at a hotel or an STR located further away would generate up to 166 percent of the criteria air pollutant emissions and GHG emissions that would be generated if visitors stayed at the existing STRs.
13 Therefore, the ban has the potential to considerably increase emissions in the area. The increase in VMT and greenhouse gas emissions is directly inconsistent with regional and state goals to reduce VMT and greenhouse gas emissions from vehicle trips. Additional calculation details can be found in Appendix A.

Table 1. Emissions Increase due to Additional VMT
Criteria Air Pollutant Percent of daily mobile emissions to serve the same population
VOC 165%
NOx 165%
CO 165%
SOx 166%
PM10 166%
PM2.5 166%
GHG (CO2e) 166%
8 Airbtics 2025. Beverly Hills. Available at: https://app.airbtics.com/airbnb-data/UnitedStates/CA/Beverly%20Hills 9 Institute of Transportation Engineers (ITE). 2021. Trip Generation Manual, 11th Edition. 10 Population estimates were calculated based on an average STR capacity of 5.0 occupants and 63% occupancy rate, as indicated by Airbnb-specific data for Beverly Hills. For hotels, an average room capacity of 3 guests was assumed, reflecting typical room configurations that accommodate either 2 or 4 people. 11 CalEEMod is a land use emissions calculator developed for the California Air Pollution Control Officers Association (CAPCOA) to estimate GHG and criteria air pollutant emissions associated with both construction and operational activities from land use projects. CalEEMod provides detailed emissions estimates and default data for evaluating emissions based on region. It encompasses emissions from a variety of sources including vehicle traffic, energy use, area sources, waste disposal, and water use along with construction equipment. 12 Five miles is a conservative estimate based on the fact that many nearby Cities with less strict STR regulations are approximately 3 to 7 miles away from Beverly Hills. 13 This percent increase is independent of the number of short-term rentals in Beverly Hills. The number of shortterm rentals and population are provided for illustrative purposes only. “P
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4 An STR Ban Will Disproportionally Burden Environmental Justice Communities Existing environmental and socioeconomic disparities across Los Angeles County leave certain communities particularly vulnerable to the cumulative impacts of land use and policy changes. The proposed STR ban in Beverly Hills raises critical environmental justice concerns, particularly given Los Angeles County’s existing burdens from regional and localized traffic-related pollution. By forcing visitors out of STRs and into areas highly concentrated with hotels in Beverly Hills and nearby communities, the proposed ban will increase the existing environmental justice burdens, including high housing costs, localized traffic exposure, and air pollution.

The California Office of Environmental Health Hazard Assessment (OEHHA) CalEnviroScreen (CalEnviroScreen 4.0) is a statewide mapping tool developed to identify communities most impacted by pollution sources and other environmental health risks to identify vulnerability to adverse health effects from those sources. 14 CalEnviroScreen considers environmental and socioeconomic factors to develop a percentile of burden across the State of California. Factors include indicators of pollution burden (e.g., ozone, traffic, pesticides, drinking water) and population characteristics (e.g., asthma, cardiovascular disease, education, poverty). These metrics are scored and weighted to produce an overall CalEnviroScreen score, which can be viewed as individual contributions of pollution burden and population characteristic scores. Communities are classified as “disadvantaged” if they fall within the highest 25 percent of overall CalEnviroScreen scores, were previously designated as disadvantaged under California state law, or meet alternative
In Beverly Hills, existing hotels are predominately located southeast of Santa Monica Blvd and along Wilshire Blvd. Census tracts southwest of Beverly Hills in Santa Monica along the Santa Monica Freeway and northeast of Beverly Hills in Hollywood and Hollywood Hills along U.S. Route 101 and Santa Monica Blvd also house a high concentration of hotels. The proposed ban on STRs may lead additional proposed visitors to seek hotel stays in these locations. Many of these hotel-dominated areas show elevated burden compared to other parts of the community according to CalEnviroScreen and some are classified as disadvantaged under California Senate Bill 535.15 As shown in Figure 1, the CalEnviroScreen tool identifies portions of Beverly Hills south of Santa Monica Blvd as more burdened compared to those north of the roadway. These southern census tracts are also where most Beverly Hills hotels are located. While all census tracts within Beverly Hills are ranked at or below the 50th percentile for the CalEnviroScreen overall score, census tracts with more hotels are ranked higher (Tract 6037700801 44th and Tract 6037700802 50th) compared to those where most STRs are currently found (Tract 6037700700 31st and Tract 6037700600 27th). A higher score or percentile ranking means that a census tract faces increased burden compared to those tracts with lower scores.

These disparities are driven by differences in socioeconomic burden. These tracts between Santa Monica and Wilshire Boulevards are ranked above the 80th percentile for housing burden, linguistic isolation, unemployment, or a combination of these indicators (Tract 6037700801 87th percentile for linguistic isolation and housing burden, Tract 6037700801 89th percentile for housing burden and 84th percentile for unemployment). Those north of Santa Monica Blvd are ranked below the 40th percentile with Tract 6037700700 falling in the 4th percentile for housing burden and 6th percentile for 14 OEHHA. CalEnviroScreen 4.0. May 2023. Available at:
https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. 15 OEHHA. SB 535 Disadvantaged Communities. May 2022. Available at:
https://oehha.ca.gov/calenviroscreen/sb535
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unemployment. The proposed ban on STRs will have a greater impact on the communities in Beverly Hills already experiencing greater relative burden. The influx of visitors to hotels in these census tracts due to the ban will increase traffic and air pollutant emissions, as detailed in Section 3 and Section 7.

These disproportionate impacts are a critical environmental justice concern.

Figure 1. OEHHA CalEnviroScreen 4.0, Beverly Hills, CA, overall percentile of exposure and burden.

All census tracts in Beverly Hills also experience elevated pollution burden driven by diesel particulate matter, toxic releases, hazardous waste, and PM2.5. As a result of eliminating STRs, new hotels may be constructed to meet visitor demand, which exacerbates pollution and environmental concerns due to construction activity in already populated areas. Vehicle traffic into and out of the heavily-touristed neighborhood could also increase as visitors choose to stay in STRs in communities where regulations are not as strict. These visitors would have to drive into Beverly Hills to visit destinations, increasing traffic along major roadways compared to if they stayed within the neighborhood and only had to drive short distances along local streets. This could worsen the quality of life for those populations experiencing greater socioeconomic burden and exacerbate already elevated air pollution levels.

In addition to environmental justice concerns within Beverly Hills, the proposed STR ban could worsen air pollution and exposure burden in nearby Hollywood, Culver City, and Santa Monica, as demonstrated in Figure 2. Beverly Hills, in addition to being a popular neighborhood for STRs, is a common tourist destination due to its fame for celebrity residents, high-end shopping along Rodeo “P
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Drive, and the historic Beverly Hills Hotel.16 Because of the proposed ban, visitors who would have previously stayed in Beverly Hills may stay in adjacent communities with similar amenities, less restrictions on STRs, and access to tourist destinations, shifting the impact of their visits into communities already experiencing elevated pollution and exposure burden. Many nearby hotels are in census tracts classified as disadvantaged under California Senate Bill 535, 17 such as Tract 6037190801
in Hollywood (95th overall percentile and 98th percentile for diesel particulate matter exposure) and Santa Monica’s Tract 6037701801 (85th overall percentile and 96th percentile for pollution burden).

Increased traffic and disruption from hotel visitors because of the ban would directly impact some of California’s most polluted census tracts.

Figure 2. Communities classified as disadvantaged near Beverly Hills, CA, under California Senate Bill 535.18
Similarly, by requiring visitors to Beverly Hills to stay elsewhere and drive into the neighborhood, the proposed ban on STRs could worsen exposure burdens associated with traffic impacts along Santa Monica Blvd, US-101, and I-405. As shown in Figure 3, many tracts along I-405 and US-101 are ranked above the 90
th percentile for traffic impacts. Beverly Hills also experiences above average traffic burden, ranking above the 64th percentile. In CalEnviroScreen, the traffic impact score 16 Paula Vars. Discover the Reasons why Beverly Hills is Famous. September 2024. Available at:
https://www.beverlene.com/discover-the-reasons-why-beverly-hills-is-famous 17 OEHHA. SB 535 Disadvantaged Communities.
18 OEHHA. SB 535 Disadvantaged Communities. May 2022. Available at:
https://oehha.ca.gov/calenviroscreen/sb535
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represents the average number of vehicles per hour per kilometer of roadway passing through the census tract.
19 Those living in communities ranked above the 90th percentile experience as many as 45,000 vehicles/kilometer passing through their neighborhood every hour.20 Increased visitor movement to and from Beverly Hills as a result of the STR ban could concentrate traffic in these census tracts and worsen exposure to air pollution associated with poor lung function, asthma, and worse birth outcomes.
21,22,23,24,25
Figure 3. OEHHA CalEnviroScreen 4.0, Beverly Hills, CA, exposure indicator of traffic impacts. 19 OEHHA. CalEnviroScreen 4.0. October 2021. Available at:
https://oehha.ca.gov/sites/default/files/media/downloads/calenviroscreen/report/calenviroscreen40reportf2021.pdf 20 OEHHA. CalEnviroScreen 4.0. October 2021. Available at:
https://oehha.ca.gov/sites/default/files/media/downloads/calenviroscreen/report/calenviroscreen40reportf2021.pdf 21 Schultz et al. 2012. Traffic-Related Air Pollution and Lung Function in Children at 8 Years of Age. American Journal of Respiratory and Critical Care Medicine, 186(12), 1286–91. Available at:
https://doi.org/10.1164/rccm.201206-1045OC
22 Kan et al. 2007. Traffic Exposure and Lung Function in Adults: The Atherosclerosis Risk in Communities Study.

Thorax, 62(10), 873–79. Available at: https://doi.org/10.1136/thx.2006.073015. 23 Garcia et al. 2019. Association of Changes in Air Quality With Incident Asthma in Children in California. JAMA, 321(19), 1906–15. Available at: https://doi.org/10.1001/jama.2019.5357. 24 Ghosh et al. 2012. Assessing the Influence of Traffic-Related Air Pollution on Risk of Term Low Birth Weight on the Basis of Land-Use-Based Regression Models and Measures of Air Toxics. American Journal of Epidemiology, 175(12), 1262–74. Available at: https://doi.org/10.1093/aje/kwr469 25 Ritz et al. 2007. Ambient Air Pollution and Preterm Birth in the Environment and Pregnancy Outcomes Study at the University of California, Los Angeles. American Journal of Epidemiology, 166(9), 1045–52. Available at:
https://doi.org/10.1093/aje/kwm181.
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The proposed ban on STRs in Beverly Hills could shift visitor accommodations in STRs from lowerburdened, dispersed residential areas to concentrated hotel zones along Santa Monica Blvd and Wilshire Blvd as well as to adjacent communities like Hollywood and Santa Monica where pollution and traffic emission levels are already elevated. This shift in accommodation location could increase vehicular traffic and hotel-generated emissions in areas facing significant burden associated with air pollution exposure levels and health risks. Furthermore, the construction of more hotels in this area to meet the demands of visitors due to the STR ban could increase emissions from construction and operation in these areas. Together, the relocation of visitor travel and construction of new hotels could further contribute to respiratory and cardiovascular health risks in Beverly Hills and overburdened communities throughout coastal and southwest Los Angeles County. 5 An STR Ban Would Increase Energy Demands and Overall Environmental Impact of a Visitor Traveling to the Area
As a result of the proposed STR ban, visitors who would have otherwise stayed in STRs may choose to stay in hotels that consume more energy per person than STRs. Using CalEEMod, Ramboll modeled the operational GHG emissions of hotels and STRs for comparison. The single-family home CalEEMod land use type was used a surrogate for STR. Assuming an occupancy rate of 3 people per hotel room and 5.0 people per STR, hotels have much higher associated GHG emissions per person. It was found that hotels consume more electricity and natural gas per person than STRs, as shown in Table 2 and in the calculations and CalEEMod output in Appendix B.
26 Table 2. Operational Energy Use per Person
Land Use
Electricity Natural Gas CO2e
kWh/yr/person kBTU/yr/person MT/yr/person
Hotel 5,655 11,718 1,745
Short Term Rentals 1,327 10,652 847
Percent Increase 326% 10% 106%
As a result of the increase in energy consumption when staying in a hotel instead of an STR, per visitor electricity consumption would increase by 326 percent and GHG emissions would increase by 106 percent.

Additionally, the STR ban in Beverly Hills will increase the overall environmental impact of a visitor traveling to the area due to water consumption and waste production. Hotel accommodations typically require more frequent towel and linen washing compared to STR accommodations. Hotels often use single-use items such as coffee filters, shampoos, and soap which result in a large amount of waste per room when compared to a STR, where single-use items are not needed. Additionally, most STRs are single family homes with recycling services and provide recycling bins. Hotels do not often provide recycling bins in addition to waste bins.
26 The CalEEMod analysis is based on 150 dwelling units, which is the amount of STRs that would accommodate the same number of people as a 250 room hotel. However, the energy use per person and percent increase in GHG emission is independent of the absolute number of short-term rentals in Beverly Hills. “P
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As mentioned above, hotels also tend to produce more VMT per person because visitors make more trips from their hotel to restaurants, stores, and other attractions compared to STRs, which results in additional emissions.
6 An STR Ban Will Increase Fossil Fuel Usage
In addition, increased VMT would require greater reliance on fossil fuels to power vehicle trips. Even with California’s policies to shift the vehicle fleet towards cleaner cars and trucks, vehicle usage will continue to rely on gasoline for car and truck trips for years to come. The STR ban therefore results in greater reliance on fossil fuels, inconsistent with regional and state climate policy. The estimated fuel use is summarized in Table 3 and utilizes the same assumptions from Table 1. Additional calculation details can be found in Appendix A.
27 Table 3. Daily Mobile Fuel Consumption
Land Use
Gasoline Diesel
Gallons per day Gallons per day
Short Term Rentals without Ban 1,353 72
After Ban 2,240 119
Percent of fuel consumption to
serve the same population 166% 166%
7 An STR Ban Could Concentrate Traffic Resulting in Potential Noise and Health Impacts
The potential ban of short-term rentals in Beverly Hills could result in concentrated traffic on roadways, which could have noise and health impacts to the surrounding land uses. As described above, removing short term rentals as a means for lodging in Beverly Hills would result in visitors needing to rely on hotels for their stay or traveling to other areas to stay at an STR. Currently, there are approximately 20 hotels in the city limits of Beverly Hills and over half of them are located in along Santa Monica Boulevard. It can be assumed that if more people will need to stay in hotels instead of STRs, then the traffic to this part of town would increase significantly as it is likely all of this traffic would be concentrated to the roadways surrounding the hotel zone area. In comparison, traffic caused from visitors traveling to and from various STRs located throughout the City would result in more diversified traffic patterns as all visitors are not driving to one area. Furthermore, if STRs are eliminated, more vehicles would travel along Santa Monica Boulevard (Highway 2) to reach other STRs located farther away. Highway 2 is the main route to many destinations in the City and surrounding areas. In comparison, traffic caused from visitors traveling to and from various STRs located throughout the City would result in more diversified traffic patterns as all visitors are not driving to one area. Furthermore, a potential new hotel constructed to meet the demand as a result of the STRs ban would likely be constructed in the area of Beverly Hills in the popular hotel zones, further concentrating traffic in these areas.
27 The fuel usage is based on 854 STRs in Beverly Hills. However, the percent increase is independent of the number of short-term rentals in Beverly Hills.
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Health Risk Impacts from Traffic
Ramboll performed a preliminary analysis that quantified the health risks from traffic emissions in order to assess the potential impact of increased hotel use in Beverly Hills due to a ban on STRs. A typical roadway with approximately 30,000 average annual daily trips (AADT) results in an excess cancer risk of 40 in a million at a nearby residential receptor.28,29,30 According to ITE, hotels generate

7.99 trips per day per hotel room.31 The SCAQMD has a CEQA threshold of significance for cancer risk of 10 in a million. To remain below the thresholds, less than 7,650 additional vehicles per day could travel on Highway 2 as a result of the STR ban. This equates to about 950 hotel room stays or 595 STRs used in other areas.

Replacing even a portion of these STRs with hotel accommodations would result in increased traffic volumes that could result in significant health impacts. This scaling approach does not account for additional vehicle activity associated with hotel operations, such as frequent commercial deliveries of food, beverages, linens, housekeeping supplies, and other goods that service on-site restaurants, conference spaces, and guest amenities. In contrast, STRs typically do not generate the same volume or type of service traffic, as guests often prepare their own meals or use nearby restaurants and grocery stores. If these additional hotel-related trips were included in the analysis, the total traffic volume and associated cancer risk would be higher. Accounting for the additional trips from hotel operation would further reduce the number of hotel rooms that could be accommodated without exceeding risk thresholds. Therefore, further restricting STRs in Beverly Hills could result in an increase in traffic on certain roadways with potentially significant health impacts.

Although this analysis focuses on cancer risk, similar exposure patterns would be expected for particulate matter and toxic air contaminant emissions, suggesting that other health impacts may increase if STR restrictions shift visitor accommodations towards hotel zones and STRs farther away.

Noise Impacts from Traffic
Ramboll evaluated whether a potential traffic volume increase could cause a traffic noise increase that is considered either substantial (per CEQA guidelines) or increases the ambient conditions to a level above the Beverly Hills General Plan Noise Element standard (60 dBA CNEL for residential land uses).32
Traffic noise analyses require specific knowledge of existing and future traffic volumes and vehicle mixes as well as project-related traffic volumes and mixes. In this case, this information is currently unknown. However, the following figure shows the best available exterior levels of noise created by traffic traveling along roadways in the City. The City’s noise and land use compatibility standards consider exterior levels above 60 dBA (CNEL) to be generally incompatible for residential and other noise-sensitive land uses.
28 Health impacts obtained from highway 152 from the Bay Area Air Quality Management District (BAAQMD) Mobile Source Screening tool at a distance of 100 feet from the roadway. This was used as a surrogate to estimate general health risks from only traffic. The traffic volume along this road was obtained from CalTrans. 29 Bay Area Air Quality Management District (BAAQMD). 2022. CEQA Roadway Screening Tool - Cancer Risk.

Available at: https://data.bayareametro.gov/Environment/CEQA-Roadway-Screening-Tool-Cancer-Risk/kz4aueki 30 CalTrans, Traffic Census Program. Available at: https://dot.ca.gov/programs/traffic-operations/census. 31 ITE. Trip Generation Manual 11th Edition.
32 City of Beverly Hills. 2010. General Plan Chapter 8, Noise. Available at:
https://beverlyhills.org/DocumentCenter/View/5513/08-Noise-PDF “P
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If residential or other noise-sensitive areas within the City that are currently below the 60 dBA CNEL level experienced traffic volume increases, specifically due to an increased hotel demand resulting from the proposed STR ban, and the traffic volume increase caused the CNEL level to increase, the STR ban could be considered to have caused a significant impact. The Beverly Hills Noise Element establishes that a significant noise impact on a noise-sensitive receptor occurs when there is an increase in CNEL, as shown in the table below.

Table 5. Beverly Hills Noise Element CNEL
CNEL (dBA) dBA Increase
55 3
60 2
65 1
70 1
Over 75 1
The magnitude of a traffic noise increase is dependent on several factors including the traffic volume increase, the vehicle mix, and the local site conditions. Based on standard methodologies prescribed by the Federal Highway Administration (FHWA) and considering a vehicle mix typical of suburban/urban areas, traffic volume increases would be expected to result in the following traffic noise increases.

Table 6. Noise Impact from Traffic Increase
Traffic Volume Increase Potential Traffic Noise
Increase
25% 1 dB
50% 2 dB
100% 3 dB
Project-specific detailed analysis, including a traffic analysis, would be required to further evaluate noise impacts. Nonetheless, the volume increases listed below suggest the traffic increases likely required to increase the existing traffic noise conditions would need to be substantial. As shown in the Figure below, the majority of the existing hotel stock is located southeast of Santa Monica Blvd and along Wilshire Blvd in areas already above the noise standard of 60 dBA or near the standard.

Therefore, adding additional traffic to this area due to the shift to hotels as a result of the STR ban or the addition of new hotels to the area has the potential to exacerbate the existing noise impacts or create a new noise impact. Therefore, this should be studied in more detail. “P
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Figure 4. Contours from the Noise Element. Source: Noise Element, Beverly Hills General Plan, April 2010 (https://www.beverlyhills.org/1067/General-Plan-Document). 8 Elimination of Short-Term Rentals Could Cause the Construction of New Hotels to Meet Demand; the Construction of New Hotels Would Result in Numerous Environmental Impacts That Require Studying
The prohibition of STRs, including those currently operating within the City, could compel tourists to seek alternative accommodations, increasing demand for hotels and potentially leading to the development of additional hotels as a reasonably foreseeable consequence of the STR ban. The construction of hotels has impacts on the environment that have not been studied. In particular, construction of hotels has potential noise and air quality impacts as discussed below.

Potential Hotel Construction Air Quality and Health Impacts Resulting from STR Ban Ramboll performed a screening health risk assessment to determine the potential cancer risk resulting from construction activity of a hypothetical new hotel. The emissions associated with the construction of these hotels encompass on-site, off-road heavy equipment, off-site, on-road vehicle travel, architectural coating, paving, and fugitive dust. Ramboll utilized CalEEMod to estimate construction emissions from a 250-room hotel as shown in Appendix B, which is an average mid-size hotel. “P
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Ramboll used an existing hotel project site to model emissions in AERMOD as a surrogate for the space of hotel construction. Concentrations resulting from diesel particulate matter (DPM) emissions from off-road construction equipment in CalEEMod were modeled on receptors in a grid of 20 meters.

The health risk assessment used default exposure assumptions for residents as outlined by OEHHA.33 As indicated in Table 6, the construction of a hotel without emissions mitigation results in an excess cancer risk of 31 in a million for the maximum exposed individual (MEI), which exceeds the SCAQMD’s threshold of 10 in a million. Cancer risks continue to exceed the threshold until a distance of 450 feet from the construction area.
34 Table 6. Cancer Risk from Hotel Construction
Source Cancer Risk (in a million)
Construction of a 250 room Hotel 31
SCAQMD Threshold of Significance 10
Potential Noise Impacts due to New Hotels Resulting from STR Ban Land Use Compatibility per the City of Beverly Hills Noise Element California Government Code encourages each local government entity to implement a noise element as part of its general plan. In addition, the California Governor’s Office of Land Use and Climate Innovation has developed guidelines for preparing noise elements, which include recommendations for evaluating the compatibility of various land uses as a function of community noise exposure. The City of Beverly Hills has established a Noise Element as part of the Beverly Hills General Plan.35 The Noise Element works to ensure that the City limits the exposure of the community to excessive noise levels in noise-sensitive areas and at noise-sensitive times of day. Specifically, the City has established standards for noise levels (Community Noise Equivalent Level [CNEL], dBA) for land uses as displayed in Figure 6.

Sound levels resulting from a project that exceed the standards listed in Figure 6 or that cause the existing conditions to increase above these standards would typically be considered to be impacting the surrounding community.
33 OEHHA. 2015. Air Toxics Hot Spots Program. Risk Assessment Guidelines. Guidance Manual for Preparation of Health Risk Assessments. February.
34 The results presented here are based on pollutant dispersion using the John Wayne Airport meteorological data performed for an analysis in Santa Ana, CA. However, since Santa Ana and Beverly Hills are located within the same geography and likely have similar meteorological settings, the results determined for the Santa Ana study is representative of a new hotel constructed in Beverly Hills. 35 City of Beverly Hills. 2010. General Plan Chapter 8, Noise. Available at:
https://beverlyhills.org/DocumentCenter/View/5513/08-Noise-PDF “P
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Figure 5. Noise Standards from the Noise Element. Source: Noise Element, Beverly Hills General Plan, April 2010.

Analysis of Construction Noise associated with the Building of New Hotels The effect of construction noise impacts on nearby noise-sensitive neighbors is dependent on the location and nature of the construction activities. Depending on the construction activities and neighboring land uses, there is a potential for possible significance threshold exceedances related to the resulting construction activities, particularly in relation to residential communities.

Noise emissions from construction activities are not regulated by the Beverly Hills Code of Ordinances.

However, a permit is required to perform any construction activities during nighttime hours (between 6:00 P.M. and 8:00 A.M.). The potential for substantial temporary increases to the existing ambient conditions could be considered relative to CEQA guidelines.

Construction typically involves the use of heavy machinery that can be a significant source of noise and, while often temporary, can result in significant impacts. Construction equipment commonly includes air compressors, backhoes, concrete trucks, cranes, dump trucks, excavators, graders, pavers, tractors/dozers, vibratory rollers, portable generators, and water trucks. Depending on the phase of construction, project construction typically involves a combination of these types of off-road and portable construction equipment. Assuming a typical construction plan, common types of construction equipment, and typical construction equipment sound levels published by resources such as the U.S. Federal Highway Administration, the Federal Transit Administration, and manufacturers, potential overall sound levels can be estimated. Accordingly, construction sound levels could range from approximately 75 to 90 dBA assuming typical receptor distances of 500 ft to 50 ft. Construction activities also may need to occur at night due to various limitations. Examples include concrete pours that need to occur when other construction is not happening or would impede traffic or roadway construction work that needs to occur at nighttime.

The table below outlines general construction phasing and equipment assumptions employed to estimate approximate sound pressure levels (SPL) for common construction phases for a hotel use as “P
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generated in CalEEMod.
36 It is anticipated that these sound pressure levels are above typical suburban/urban ambient sound levels and therefore could cause a temporary increase above the threshold discussed above. For reference, typical suburban/urban background sound levels are commonly on the order of 45 to 55 dBA during daytime hours and lower during nighttime hours.37 Because sound pressure levels from construction of a new hotel, which was needed due to a STR ban, have the potential to cause a temporary increase above the noise level threshold, more analysis is needed to evaluate specific impacts and potential mitigation. While construction may be exempt from the noise ordinance during daytime hours, the table below shows that the construction could have a significant noise impact on the community.

Furthermore, if any nighttime construction activity is needed for the hotel, the noise levels below show that threshold for nighttime work in the noise ordinance would be exceeded.

Table 7. Noise Impacts from Construction Activity
Construction
Phase
Equipment Type Qty
Avg.

Usage
Hours
per
Day
Size,
Hp
Equip
Lmax
SPL @
50 ft
dBA
Acoustical
Use
Factor
Equip
SPL @
50 ft
dBA
Total
SPL @
50 ft
dBA
Total
SPL @
50 ft
dBA
Total
SPL @
500 ft
dBA
Site
Preparation
Rubber Tired Dozers 3 8 367 85 40% 81 86
Tractors/Loaders/Bac 89 79
khoes
4 8 84 84 40% 80 86
Grading
Excavators 2 8 36 85 40% 81 84
90 80
Graders 1 8 148 85 40% 81 81
Rubber Tired Dozers 1 8 367 85 40% 81 81
Scrapers 2 8 423 85 40% 81 84
Tractors/Loaders/Bac
khoes
2 8 84 84 40% 80 83
Building
Construction
Cranes 1 7 367 83 16% 75 75
87 77
Forklifts 3 8 82 75 40% 71 76
Generator Sets 1 8 14 82 50% 79 79
Tractors/Loaders/Bac
khoes
3 7 84 84 40% 80 85
Welders 1 8 46 74 40% 70 70
Paving
Pavers 2 8 81 85 50% 82 85
Paving Equipment 2 6 89 85 50% 82 85 89 79
Rollers 2 6 36 85 20% 78 81
36 California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod®), Version 2022.1. Available online at https://www.caleemod.com/ . 37 U.S. Environmental Protection Agency, Community Noise, December 31, 1971.

APPENDIX A

CALCULATION DETAILS
Appendix Table A1: VMT and Mobile Emissions Comparison of Short Term Rentals and Hotels VOC NOx CO SOx PM10 PM2.5 CO2e
Short Term
Rental Existing 5 854 STRs 63% 2,690 9.9 3.55 3,032 29,991 Short Term
Rental 5 269 STRs -- 1,345 14.9 3.55 955 14,222
Hotel 3 448 Hotel
Rooms -- 1,345 9.9 7.99 3,582 35,438
Notes:

Abbreviations:

CalEEMod - California Emissions Estimator Model NOx - nitrogen oxide compounds (NO + NO2) STR - short term rental CO - carbon monoxide PM2.5 - particulate matter less than 2.5 microns in diameter VOC - volatile organic compounds CO2e - carbon dioxide equivalents PM10 - particulate matter less than 10 microns in diameter VMT - vehicle miles traveled ITE - Institute of Transportation Engineers SOx - sulfur oxide compounds References:

Airbtics 2025. Beverly Hills. Available at: https://app.airbtics.com/airbnb-data/united-states/CA/beverly%20hills ITE. Trip Generation Manual 11th Edition.

California Air Resources Board (ARB) 2025. EMFAC2025. Available at: https://arb.ca.gov/emfac/ California Air Resources Board (ARB) 2024. GHG Global Warming Potentials. Available at: https://ww2.arb.ca.gov/ghg-gwps 6 Percent changes in emissions under the proposed ban were calculated for criteria air pollutants and carbon dioxide equivalents. Emissions were determined using EMFAC2025 emission factors for Los Angeles County in 2026.

Global Warming Potentials were taken from CARB guidance. The variation in the percentages between pollutants is due to the ratio of gram per trip and gram per mile emission factors for each pollutant. 165% 165% 166% 166% 166%
5 The number of peak daily VMT was determined by multiplying the daily trips by the trip length. 4 The number of peak daily trips was determined by multiplying the trip rate by the number of STRs or number of hotel rooms. 3 Daily trip rate for Recreational Homes (ITE Land Use 260) and Hotel (ITE Land Use 310). 2 Trip distances assume CalEEMod default trip lengths in Beverly Hills. For this comparison, it is assumed that visitors staying at future STRs farther away must travel at least five additional miles to get to a STR located outside of the STR restriction jurisdiction. This assumption is based on the proximilty to nearby cities that allow STRs. The trip distance for hotels is conservatively assumed to be the same as that for existing STRs. 1 There are 854 active STRs within the City of Beverly Hills, and the average capacity is 5.0 people per STR. It is assumed that as a result of the STR restriction, guests would stay in hotels or in STRs located further away. To compare current and future STR and hotel VMT, scenarios must be evaluated on an equivalent per capita basis. The number of future hotel rooms and STRs required to accommodate the total existing STR capacity is 448 hotel rooms and 269 STRs, assuming an average occupancy rate of 3 people per hotel room. The percent increase in emissions remains constant regardless of the number of displaced STRs. 166%
Future
Population
Capacity1
Trip Rate3
(trips/day)
Percent of Operational Emissions under Proposed Ban
Compared to Existing STR Use to serve the same
Population6
Peak Daily
Trips4
(one-way
trips/day)
Peak Daily
VMT5
(miles/day)
Trip
Distance2
Land Use (miles)
Assumed
Occupancy
Rate
Population
Rate1
(per STR or
hotel room)
165%
Quantity Unit
Appendix Table A2: VMT and Fuel Consumption Comparison of Short Term Rentals and Hotels Percent of Fleet1,2 Fuel Consuption2
(gal/mile)
94% 0.048
6% 0.037
Peak Daily VMT3
(miles/day)
Gasoline Consumption
(gal)4
Diesel Consumption
(gal)4
Short Term Rental Existing 29,991 1,353 72
Short Term Rental
Hotel
Notes:

Abbreviations:

STR - short term rental
VMT - vehicle miles traveled
gal - gallon
References:

Fuel
49,660
California Air Resources Board (ARB) 2025. EMFAC2025. Available at: https://arb.ca.gov/emfac/ 3 The number of peak daily VMT was determined in Appendix Table A1. 4 Gasoline and diesel consumption values are calculated by multiplying the VMT by the fuel-specific percentage and the weighted fuel consumption factor (gal/VMT) derived from EMFAC output. 1 Gasoline includes gasoline fueled vehicles and plug-in hybrids. Natural gas is excluded from this analysis due to the negligible VMT from natural gas vehicles.
2 The fleet mix and fuel consumption per mile is determined using EMFAC2025 for Beverly Hills in 2026. The fuel consumption rate is weighted based on fleet type.

Land Use
Future 2,240 119
Diesel
Gasoline
Appendix Table A3: Hotel Construction Cancer Risk Calculation Details Daily Breathing
Rate (DBR)2
Exposure
Duration (ED)3
Fraction of Time
at Home (FAH)4
Exposure
Frequency (EF)2
Averaging Time
(AT)7
ASF-Weighted
Intake Factor,
Inhalation
(IFinh)
[L/kg-day] [years] [unitless] [days/year] [days] [m3/kg-day] 3rd Trimester 361 0.25 1.00 10 0.012
0-<2 1090 0.75 1.00 10 0.11
Year 2 0-<2 1090 1.0 1.00 10 0.15
Year 1 Year 2

0.0056 --

0.0017 --

0.036 --
-- 0.00012
-- 0.00010

0.043 0.00022
AERMOD
Dispersion
Factor at MEI7
Construction
Emissions8
Average DPM
Concentration9
DPM Cancer
Potency Factor10 Cancer Risk11
(ug/m3)/
(g/s) g/s ug/m3
(mg/kg-day)-1 in a million
Year 1 3.05E-03 2.23E-01 31
Year 2 1.49E-05 1.09E-03 0.18
31 Notes:

1. 2.

3. 4.

5. 6.

7. 8.

9. 10.

11. Abbreviations:

AT - averaging time g - gram
ASF - Age Sensitivity Factor IFinh - intake factor
CalEEMod - California Emissions Estimator Module kg - kilogram DBR - daily breathing rate L - liter
DPM - diesel particulate matter m
3 - cubic meter
ED - exposure duration MEI - maximally impacted receptor EF - exposure frequency OEHHA - Office of Environmental Health Hazard Assessment FAH - fraction of time at home s - second
References:

California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod®), Version 2022.1. Available online at http://www.caleemod.com/
Riskinh = ΣCi x CF x IFinh x CPFi x ASF
Riskinh = Cancer Risk for the Inhalation Pathway (unitless) Ci = Annual Average Air Concentration for Chemical "i" ug/m3 CF = Conversion Factor (mg/ug)
IFinh = Intake Factor for Inhalation (m3/kg-day)
CPFi = Cancer Potency Factor (mg/kg-day)-1
ASF = Age Sensitivity Factor (unitless)
OEHHA. 2015. Air Toxics Hot Spots Program Risk Assessment Guidelines. Guidance Manual for Preparation of Health Risk Assessments. Available at https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf California Air Resources Board (ARB)/ California Office of Environmental Health Hazard Assessment (OEHHA). 2023. Consolidated Table of OEHHA/ARB Approved Risk Assessment Health Values. Updated on: May 1, 2023. Available at:
https://ww2.arb.ca.gov/sites/default/files/classic/toxics/healthval/contable05012023.pdf USEPA. 2022. User's Guide for the AMS/EPA Regulatory Model (AERMOD). U.S. EPA Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina.

Available at: https://gaftp.epa.gov/Air/aqmg/SCRAM/models/preferred/aermod/aermod_userguide.pdf Construction emissions were calculated in CalEEMod using default information for the construction of a mid-sized (250-room) hotel located in the hotel zone along Santa Monica Boulevard in Beverly Hills. PM10 emissions were used as a surrogate for diesel particulate matter (DPM).

The construction area was modeled as an area source in AERMOD using the John Wayne Airport met station. Using the Chi/Q method, the maximally impacted receptor was identified by the receptor with the largest dispersion factor.

The emission rate used in the cancer risk calculation is the DPM ton/year emissions converted to grams per second assuming 11 hours of construction per day, which is consistent with the City of Beverly Hills allowed construction hours of 8AM to 6PM.

The average concentration of diesel particulate matter is a product of the emission rate and the dispersion factor at the MEI.

The cancer potency factor for DPM is provided by OEHHA guidance.

Excess lifetime cancer risks were estimated using the following equation:

Total Cancer Risk
The most conservative age group is a resident child beginning at the third trimester. All nearby receptors were conservatively modeled as residents to capture the maximum risk potential.

Daily breathing rates and exposure frequency by age bin are consistent with OEHHA's Guidance Manual for Preparation of Health Risk Assessments.

Annual exposure duration represents one full year. The exposure duration for all years is 1, as the health risk assessment is based on annual emissions.

Fraction of time spent at home is conservatively assumed to be 1 (i.e., 24 hours/day) for age groups from the third trimester to less than 16 years old based on the recommendation from OEHHA.

Age Sensitive Factors account for an "anticipated special sensitivity to carcinogens" of infants and children as recommended in the OEHHA guidance.

Architectural Coating
Total
Cancer Risk Calculation
Year
73 1.1
Construction Phase6
DPM Emissionsf from
Construction
[ton/yr]
Site Preparation
Grading
Building Construction
Paving
Year
Receptor Age
Group1
Exposure Parameters
Age Sensitivity
Factor (ASF)5
Year 1
350 25500
Appendix Table B1: Energy Use and Greenhouse Gas Emissions by Dwelling Type kWh/yr kWh/yr/person kBTU/yr kBTU/yr/person MT/yr MT/yr/person Single-Family Housing 750 994,939 1,327 7,989,050 10,652 847 1.1 Hotel 750 4,240,891 5,655 8,788,466 11,718 1,745 2.3
Notes:
1 2
3 Abbreviations
kWh - kilowatt-hour
References
Total CO2e
Percent Increase3 326% 10% 106%
Land Use1 Population2 Electricity Use Natural Gas Use
STR - short-term rental
CAPCOA. 2022. CalEEMod®. Available at: https://www.caleemod.com/ Airbtics 2025. Beverly Hills. Available at: https://app.airbtics.com/airbnb-data/united-states/CA/beverly%20hills The land use types were selected to allow for the use of CalEEMod® for emissions and energy use calculations. The single-family housing land use type was used to represent a theoretical STR.

The quantity of households/rooms was determined from an assumed population of 750 individuals and an average occupancy rate of 5 guests per STR and 3 guests per hotel room in Beverly Hills.

The percent change in electricity use, natural gas use, and emissions does not vary with the number of units and is only shown for descriptive purposes.

CalEEMod® - California Emissions Estimator Model MT - metric ton CO2e - carbon dioxide equivalents

APPENDIX B

CALEEMOD REPORTS
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Hotel - Beverly Hills Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds

2.2. Construction Emissions by Year, Unmitigated

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

3. Construction Emissions Details

3.1. Site Preparation (2026) - Unmitigated

3.3. Grading (2026) - Unmitigated

3.5. Building Construction (2026) - Unmitigated

3.7. Paving (2026) - Unmitigated

3.9. Paving (2027) - Unmitigated
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3.11. Architectural Coating (2027) - Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type
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4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.1. Construction Schedule

5.2. Off-Road Equipment

5.2.1. Unmitigated

5.3. Construction Vehicles

5.3.1. Unmitigated

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies

5.5. Architectural Coatings

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
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5.6.2. Construction Earthmoving Control Strategies

5.7. Construction Paving

5.8. Construction Electricity Consumption and Emissions Factors

5.9. Operational Mobile Sources

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
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5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures
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7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores

7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data
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1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Hotel - Beverly Hills
Construction Start Date 1/1/2026
Operational Year 2027
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.70
Precipitation (days) 19.6
Location 34.07172669672134, -118.40078196624353
County Los Angeles-South Coast
City Beverly Hills
Air District South Coast AQMD
Air Basin South Coast
TAZ 4307
EDFZ 16
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.29

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Hotel 250 Room 1.00 363,000 0.00 — — —
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Enclosed Parking
Structure
250 Space 1.00 100,000 0.00 — — —

1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.20 1.80 11.9 23.8 0.04 0.33 3.19 3.52 0.29 0.78 1.06 — 6,802 6,802 0.28 0.44 15.3 6,956 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 339 339 322 131 1.71 3.73 75.7 79.4 3.68 21.8 25.5 — 250,498 250,498 13.8 39.7 14.5 262,685 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 9.29 9.29 10.4 15.0 0.04 0.24 2.64 2.88 0.22 0.70 0.91 — 6,170 6,170 0.29 0.59 5.96 6,360 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.70 1.70 1.89 2.74 0.01 0.04 0.48 0.53 0.04 0.13 0.17 — 1,021 1,021 0.05 0.10 0.99 1,053

2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Hotel - Beverly Hills Detailed Report, 7/25/2025
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Daily - — — — — — — — — — — — — — — — — — —
Summer
(Max)
2026 2.20 1.80 11.9 23.8 0.04 0.33 3.19 3.52 0.29 0.78 1.06 — 6,802 6,802 0.28 0.44 15.3 6,956 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2026 19.1 4.96 322 131 1.71 3.73 75.7 79.4 3.68 21.8 25.5 — 250,498 250,498 13.8 39.7 14.5 262,685 2027 339 339 4.35 7.13 0.01 0.17 0.51 0.53 0.16 0.12 0.19 — 1,149 1,149 0.04 0.02 0.04 1,154 Average
Daily
— — — — — — — — — — — — — — — — — —
2026 1.53 1.17 10.4 15.0 0.04 0.24 2.64 2.88 0.22 0.70 0.91 — 6,170 6,170 0.29 0.59 5.96 6,360 2027 9.29 9.29 0.04 0.12 < 0.005 < 0.005 0.01 0.02 < 0.005 < 0.005 < 0.005 — 21.8 21.8 < 0.005 < 0.005 0.02 22.0 Annual — — — — — — — — — — — — — — — — — —
2026 0.28 0.21 1.89 2.74 0.01 0.04 0.48 0.53 0.04 0.13 0.17 — 1,021 1,021 0.05 0.10 0.99 1,053 2027 1.70 1.70 0.01 0.02 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.61 3.61 < 0.005 < 0.005 < 0.005 3.64

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 19.5 18.5 6.77 71.1 0.13 0.29 10.8 11.1 0.27 2.73 3.01 85.9 21,448 21,533 9.88 0.57 603 22,552 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 15.8 15.1 7.00 47.6 0.12 0.25 10.8 11.0 0.25 2.73 2.98 85.9 20,878 20,964 9.91 0.59 568 21,955 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 17.9 17.0 6.95 60.4 0.12 0.27 10.2 10.4 0.26 2.58 2.84 85.9 20,561 20,647 9.88 0.57 582 21,646 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.27 3.11 1.27 11.0 0.02 0.05 1.85 1.90 0.05 0.47 0.52 14.2 3,404 3,418 1.64 0.09 96.4 3,584

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 6.93 6.36 4.24 48.9 0.12 0.07 10.8 10.8 0.07 2.73 2.80 — 11,794 11,794 0.59 0.48 35.9 11,987 Area 12.3 12.0 0.17 20.1 < 0.005 0.04 — 0.04 0.03 — 0.03 — 82.8 82.8 < 0.005 < 0.005 — 83.1 Energy 0.26 0.13 2.36 1.98 0.01 0.18 — 0.18 0.18 — 0.18 — 9,508 9,508 0.66 0.06 — 9,541 Water — — — — — — — — — — — 12.2 62.9 75.1 1.25 0.03 — 115 Waste — — — — — — — — — — — 73.8 0.00 73.8 7.37 0.00 — 258 Refrig. — — — — — — — — — — — — — — — — 567 567
Total 19.5 18.5 6.77 71.1 0.13 0.29 10.8 11.1 0.27 2.73 3.01 85.9 21,448 21,533 9.88 0.57 603 22,552 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 6.87 6.28 4.64 45.6 0.11 0.07 10.8 10.8 0.07 2.73 2.80 — 11,307 11,307 0.62 0.50 0.93 11,473 Area 8.70 8.70 — — — — — — — — — — — — — — — —
Energy 0.26 0.13 2.36 1.98 0.01 0.18 — 0.18 0.18 — 0.18 — 9,508 9,508 0.66 0.06 — 9,541 Water — — — — — — — — — — — 12.2 62.9 75.1 1.25 0.03 — 115 Waste — — — — — — — — — — — 73.8 0.00 73.8 7.37 0.00 — 258 Refrig. — — — — — — — — — — — — — — — — 567 567
Total 15.8 15.1 7.00 47.6 0.12 0.25 10.8 11.0 0.25 2.73 2.98 85.9 20,878 20,964 9.91 0.59 568 21,955 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 6.52 5.95 4.47 44.6 0.11 0.07 10.2 10.2 0.06 2.58 2.65 — 10,934 10,934 0.59 0.48 14.8 11,107 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Area 11.2 11.0 0.12 13.8 < 0.005 0.02 — 0.02 0.02 — 0.02 — 56.7 56.7 < 0.005 < 0.005 — 56.9 Energy 0.26 0.13 2.36 1.98 0.01 0.18 — 0.18 0.18 — 0.18 — 9,508 9,508 0.66 0.06 — 9,541 Water — — — — — — — — — — — 12.2 62.9 75.1 1.25 0.03 — 115 Waste — — — — — — — — — — — 73.8 0.00 73.8 7.37 0.00 — 258 Refrig. — — — — — — — — — — — — — — — — 567 567
Total 17.9 17.0 6.95 60.4 0.12 0.27 10.2 10.4 0.26 2.58 2.84 85.9 20,561 20,647 9.88 0.57 582 21,646 Annual — — — — — — — — — — — — — — — — — —
Mobile 1.19 1.09 0.82 8.14 0.02 0.01 1.85 1.87 0.01 0.47 0.48 — 1,810 1,810 0.10 0.08 2.45 1,839 Area 2.04 2.00 0.02 2.52 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.39 9.39 < 0.005 < 0.005 — 9.42 Energy 0.05 0.02 0.43 0.36 < 0.005 0.03 — 0.03 0.03 — 0.03 — 1,574 1,574 0.11 0.01 — 1,580 Water — — — — — — — — — — — 2.01 10.4 12.4 0.21 < 0.005 — 19.1 Waste — — — — — — — — — — — 12.2 0.00 12.2 1.22 0.00 — 42.7 Refrig. — — — — — — — — — — — — — — — — 93.9 93.9
Total 3.27 3.11 1.27 11.0 0.02 0.05 1.85 1.90 0.05 0.47 0.52 14.2 3,404 3,418 1.64 0.09 96.4 3,584

3. Construction Emissions Details

3.1. Site Preparation (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.47 1.24 11.0 11.7 0.02 0.51 — 0.51 0.47 — 0.47 — 2,065 2,065 0.08 0.02 — 2,072 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Dust
From
Material
Movement
— — — — — — 7.96 7.96 — 3.26 3.26 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.09 0.10 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 17.0 17.0 < 0.005 < 0.005 — 17.0 Dust
From
Material
Movement
— — — — — — 0.07 0.07 — 0.03 0.03 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.02 0.02 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.81 2.81 < 0.005 < 0.005 — 2.82 Dust
From
Material
Movement
— — — — — — 0.01 0.01 — < 0.005 < 0.005 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.03 0.03 0.03 0.41 0.00 0.00 0.10 0.10 0.00 0.02 0.02 — 96.3 96.3 < 0.005 < 0.005 0.01 97.5 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 17.6 3.70 311 119 1.69 3.22 67.7 70.9 3.22 18.5 21.7 — 248,337 248,337 13.8 39.7 14.5 260,515 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.80 0.80 < 0.005 < 0.005 < 0.005 0.81 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.15 0.03 2.58 0.97 0.01 0.03 0.55 0.58 0.03 0.15 0.18 — 2,041 2,041 0.11 0.33 1.97 2,143 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.13 0.13 < 0.005 < 0.005 < 0.005 0.13 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.03 0.01 0.47 0.18 < 0.005 < 0.005 0.10 0.11 < 0.005 0.03 0.03 — 338 338 0.02 0.05 0.33 355

3.3. Grading (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.70 1.42 12.9 14.0 0.02 0.58 — 0.58 0.53 — 0.53 — 2,455 2,455 0.10 0.02 — 2,463 Dust
From
Material
Movement
— — — — — — 7.08 7.08 — 3.42 3.42 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.03 0.02 0.21 0.23 < 0.005 0.01 — 0.01 0.01 — 0.01 — 40.4 40.4 < 0.005 < 0.005 — 40.5 Dust
From
Material
Movement
— — — — — — 0.12 0.12 — 0.06 0.06 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 < 0.005 0.04 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 6.68 6.68 < 0.005 < 0.005 — 6.70 Dust
From
Material
Movement
— — — — — — 0.02 0.02 — 0.01 0.01 — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.04 0.04 0.04 0.55 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 128 128 0.01 < 0.005 0.01 130 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.14 2.14 < 0.005 < 0.005 < 0.005 2.17 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.35 0.35 < 0.005 < 0.005 < 0.005 0.36 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.5. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.22 1.01 8.57 9.96 0.02 0.29 — 0.29 0.27 — 0.27 — 1,801 1,801 0.07 0.01 — 1,807 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

1.22 1.01 8.57 9.96 0.02 0.29 — 0.29 0.27 — 0.27 — 1,801 1,801 0.07 0.01 — 1,807 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
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Off-Roa 0.74 0.61 5.16 6.00 0.01 0.18 — 0.18 0.16 — 0.16 — 1,086 1,086 0.04 0.01 — 1,089 d
Equipm
ent
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.13 0.11 0.94 1.10 < 0.005 0.03 — 0.03 0.03 — 0.03 — 180 180 0.01 < 0.005 — 180 Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.81 0.72 0.75 12.6 0.00 0.00 2.54 2.54 0.00 0.60 0.60 — 2,635 2,635 0.11 0.09 8.91 2,674 Vendor 0.17 0.07 2.61 1.26 0.02 0.03 0.65 0.68 0.02 0.18 0.20 — 2,366 2,366 0.10 0.34 6.39 2,475 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.81 0.71 0.85 10.7 0.00 0.00 2.54 2.54 0.00 0.60 0.60 — 2,498 2,498 0.11 0.09 0.23 2,528 Vendor 0.17 0.07 2.73 1.29 0.02 0.03 0.65 0.68 0.02 0.18 0.20 — 2,367 2,367 0.10 0.34 0.17 2,470 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.48 0.43 0.56 6.76 0.00 0.00 1.51 1.51 0.00 0.35 0.35 — 1,528 1,528 0.07 0.06 2.32 1,548 Vendor 0.10 0.04 1.65 0.77 0.01 0.02 0.39 0.41 0.01 0.11 0.12 — 1,426 1,426 0.06 0.20 1.66 1,490 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker 0.09 0.08 0.10 1.23 0.00 0.00 0.28 0.28 0.00 0.06 0.06 — 253 253 0.01 0.01 0.38 256 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Vendor 0.02 0.01 0.30 0.14 < 0.005 < 0.005 0.07 0.07 < 0.005 0.02 0.02 — 236 236 0.01 0.03 0.28 247 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.7. Paving (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.56 0.47 4.41 6.48 0.01 0.18 — 0.18 0.17 — 0.17 — 991 991 0.04 0.01 — 995 Paving 0.26 0.26 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.01 0.01 0.11 0.16 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 25.2 25.2 < 0.005 < 0.005 — 25.3 Paving 0.01 0.01 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.02 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 4.18 4.18 < 0.005 < 0.005 — 4.19 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.05 0.05 0.69 0.00 0.00 0.16 0.16 0.00 0.04 0.04 — 161 161 0.01 0.01 0.01 163 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 4.14 4.14 < 0.005 < 0.005 0.01 4.20 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.69 0.69 < 0.005 < 0.005 < 0.005 0.70 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.9. Paving (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Off-Roa
d
Equipm
ent

0.54 0.46 4.30 6.49 0.01 0.17 — 0.17 0.16 — 0.16 — 992 992 0.04 0.01 — 995 Paving 0.26 0.26 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.02 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 3.88 3.88 < 0.005 < 0.005 — 3.89 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.64 0.64 < 0.005 < 0.005 — 0.64 Paving < 0.005 < 0.005 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.04 0.05 0.64 0.00 0.00 0.16 0.16 0.00 0.04 0.04 — 157 157 < 0.005 0.01 0.01 159 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.63 0.63 < 0.005 < 0.005 < 0.005 0.63 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.10 0.10 < 0.005 < 0.005 < 0.005 0.10 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

3.11. Architectural Coating (2027) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent

0.14 0.11 0.83 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coating
s
339 339 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 0.02 0.03 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 3.66 3.66 < 0.005 < 0.005 — 3.67 Architect
ural
Coating
s

9.28 9.28 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Roa
d
Equipm
ent
< 0.005 < 0.005 < 0.005 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.61 0.61 < 0.005 < 0.005 — 0.61 Architect
ural
Coating
s

1.69 1.69 — — — — — — — — — — — — — — — —
Onsite
truck

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.15 0.14 0.17 1.98 0.00 0.00 0.51 0.51 0.00 0.12 0.12 — 490 490 0.01 0.02 0.04 496 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.06 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 13.6 13.6 < 0.005 < 0.005 0.02 13.8 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 2.26 2.26 < 0.005 < 0.005 < 0.005 2.28 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hotel 6.93 6.36 4.24 48.9 0.12 0.07 10.8 10.8 0.07 2.73 2.80 — 11,794 11,794 0.59 0.48 35.9 11,987 Enclose
d
Parking
Structure

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 6.93 6.36 4.24 48.9 0.12 0.07 10.8 10.8 0.07 2.73 2.80 — 11,794 11,794 0.59 0.48 35.9 11,987 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hotel 6.87 6.28 4.64 45.6 0.11 0.07 10.8 10.8 0.07 2.73 2.80 — 11,307 11,307 0.62 0.50 0.93 11,473 Enclose
d
Parking
Structure

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Total 6.87 6.28 4.64 45.6 0.11 0.07 10.8 10.8 0.07 2.73 2.80 — 11,307 11,307 0.62 0.50 0.93 11,473 Annual — — — — — — — — — — — — — — — — — —
Hotel 1.19 1.09 0.82 8.14 0.02 0.01 1.85 1.87 0.01 0.47 0.48 — 1,810 1,810 0.10 0.08 2.45 1,839 Enclose
d
Parking
Structure

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.19 1.09 0.82 8.14 0.02 0.01 1.85 1.87 0.01 0.47 0.48 — 1,810 1,810 0.10 0.08 2.45 1,839

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — — 6,181 6,181 0.38 0.05 — 6,204 Enclose
d
Parking
Structure
— — — — — — — — — — — — 510 510 0.03 < 0.005 — 512
Total — — — — — — — — — — — — 6,691 6,691 0.42 0.05 — 6,717 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — — 6,181 6,181 0.38 0.05 — 6,204 Enclose
d
Parking
Structure
— — — — — — — — — — — — 510 510 0.03 < 0.005 — 512
Total — — — — — — — — — — — — 6,691 6,691 0.42 0.05 — 6,717 Annual — — — — — — — — — — — — — — — — — —
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Hotel — — — — — — — — — — — — 1,023 1,023 0.06 0.01 — 1,027 Enclose
d
Parking
Structure
— — — — — — — — — — — — 84.5 84.5 0.01 < 0.005 — 84.8
Total — — — — — — — — — — — — 1,108 1,108 0.07 0.01 — 1,112

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hotel 0.26 0.13 2.36 1.98 0.01 0.18 — 0.18 0.18 — 0.18 — 2,817 2,817 0.25 0.01 — 2,824 Enclose
d
Parking
Structure

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.26 0.13 2.36 1.98 0.01 0.18 — 0.18 0.18 — 0.18 — 2,817 2,817 0.25 0.01 — 2,824 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hotel 0.26 0.13 2.36 1.98 0.01 0.18 — 0.18 0.18 — 0.18 — 2,817 2,817 0.25 0.01 — 2,824 Enclose
d
Parking
Structure

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.26 0.13 2.36 1.98 0.01 0.18 — 0.18 0.18 — 0.18 — 2,817 2,817 0.25 0.01 — 2,824 Annual — — — — — — — — — — — — — — — — — —
Hotel 0.05 0.02 0.43 0.36 < 0.005 0.03 — 0.03 0.03 — 0.03 — 466 466 0.04 < 0.005 — 468 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Enclose 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 d
Parking
Structure
Total 0.05 0.02 0.43 0.36 < 0.005 0.03 — 0.03 0.03 — 0.03 — 466 466 0.04 < 0.005 — 468

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Product
s

7.77 7.77 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.93 0.93 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

3.58 3.31 0.17 20.1 < 0.005 0.04 — 0.04 0.03 — 0.03 — 82.8 82.8 < 0.005 < 0.005 — 83.1 Total 12.3 12.0 0.17 20.1 < 0.005 0.04 — 0.04 0.03 — 0.03 — 82.8 82.8 < 0.005 < 0.005 — 83.1 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Product
s

7.77 7.77 — — — — — — — — — — — — — — — —
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Architect 0.93 0.93 — — — — — — — — — — — — — — — —
ural
Coating
Total 8.70 8.70 — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Consum
er
Product
s

1.42 1.42 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.17 0.17 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.45 0.41 0.02 2.52 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.39 9.39 < 0.005 < 0.005 — 9.42 Total 2.04 2.00 0.02 2.52 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 9.39 9.39 < 0.005 < 0.005 — 9.42

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — 12.2 62.9 75.1 1.25 0.03 — 115 Enclose
d
Parking
Structure
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 12.2 62.9 75.1 1.25 0.03 — 115 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Hotel — — — — — — — — — — — 12.2 62.9 75.1 1.25 0.03 — 115 Enclose
d
Parking
Structure
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 12.2 62.9 75.1 1.25 0.03 — 115 Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — 2.01 10.4 12.4 0.21 < 0.005 — 19.1 Enclose
d
Parking
Structure
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 2.01 10.4 12.4 0.21 < 0.005 — 19.1

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — 73.8 0.00 73.8 7.37 0.00 — 258 Enclose
d
Parking
Structure
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 73.8 0.00 73.8 7.37 0.00 — 258 Hotel - Beverly Hills Detailed Report, 7/25/2025
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Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Hotel — — — — — — — — — — — 73.8 0.00 73.8 7.37 0.00 — 258 Enclose
d
Parking
Structure
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 73.8 0.00 73.8 7.37 0.00 — 258 Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — 12.2 0.00 12.2 1.22 0.00 — 42.7 Enclose
d
Parking
Structure
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 12.2 0.00 12.2 1.22 0.00 — 42.7

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — — — — — — 567 567
Total — — — — — — — — — — — — — — — — 567 567
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — — — — — — 567 567
Total — — — — — — — — — — — — — — — — 567 567
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Annual — — — — — — — — — — — — — — — — — —
Hotel — — — — — — — — — — — — — — — — 93.9 93.9
Total — — — — — — — — — — — — — — — — 93.9 93.9

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Hotel - Beverly Hills Detailed Report, 7/25/2025
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Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
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Avoided——————————————————
Subtotal——————————————————
Sequest
ered
——————————————————
Subtotal——————————————————
Remove d——————————————————
Subtotal——————————————————
———————————————————
Daily,
Winter
(Max)
——————————————————
Avoided——————————————————
Subtotal——————————————————
Sequest
ered
——————————————————
Subtotal——————————————————
Remove d——————————————————
Subtotal——————————————————
———————————————————
Annual——————————————————
Avoided——————————————————
Subtotal——————————————————
Sequest
ered
——————————————————
Subtotal——————————————————
Remove d——————————————————
Subtotal——————————————————
———————————————————
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5. Activity Data

5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Site Preparation Site Preparation 1/30/2026 2/3/2026 5.00 3.00 — Grading Grading 2/4/2026 2/12/2026 5.00 6.00 —
Building Construction Building Construction 2/13/2026 12/18/2026 5.00 220 — Paving Paving 12/19/2026 1/2/2027 5.00 10.0 —
Architectural Coating Architectural Coating 1/3/2027 1/17/2027 5.00 10.0 —

5.2. Off-Road Equipment

5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Site Preparation Tractors/Loaders/Back
hoes
Diesel Average 1.00 8.00 84.0 0.37
Site Preparation Graders Diesel Average 1.00 8.00 148 0.41 Site Preparation Rubber Tired Dozers Diesel Average 1.00 7.00 367 0.40 Grading Graders Diesel Average 1.00 8.00 148 0.41
Grading Rubber Tired Dozers Diesel Average 1.00 8.00 367 0.40 Grading Tractors/Loaders/Back
hoes
Diesel Average 2.00 7.00 84.0 0.37
Building Construction Cranes Diesel Average 1.00 6.00 367 0.29 Building Construction Forklifts Diesel Average 1.00 6.00 82.0 0.20 Building Construction Generator Sets Diesel Average 1.00 8.00 14.0 0.74 Building Construction Tractors/Loaders/Back
hoes
Diesel Average 1.00 6.00 84.0 0.37
Building Construction Welders Diesel Average 3.00 8.00 46.0 0.45 Paving Pavers Diesel Average 1.00 6.00 81.0 0.42
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Paving Paving Equipment Diesel Average 1.00 8.00 89.0 0.36 Paving Rollers Diesel Average 1.00 7.00 36.0 0.38
Paving Cement and Mortar
Mixers
Diesel Average 1.00 6.00 10.0 0.56
Paving Tractors/Loaders/Back
hoes
Diesel Average 1.00 8.00 84.0 0.37
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48

5.3. Construction Vehicles

5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Site Preparation — — — —
Site Preparation Worker 7.50 18.5 LDA,LDT1,LDT2
Site Preparation Vendor — 10.2 HHDT,MHDT
Site Preparation Hauling 3,649 20.0 HHDT
Site Preparation Onsite truck — — HHDT
Grading — — — —
Grading Worker 10.0 18.5 LDA,LDT1,LDT2
Grading Vendor — 10.2 HHDT,MHDT
Grading Hauling 0.00 20.0 HHDT
Grading Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 194 18.5 LDA,LDT1,LDT2
Building Construction Vendor 75.9 10.2 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Paving — — — —
Paving Worker 12.5 18.5 LDA,LDT1,LDT2
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Paving Vendor — 10.2 HHDT,MHDT
Paving Hauling 0.00 20.0 HHDT
Paving Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 38.9 18.5 LDA,LDT1,LDT2
Architectural Coating Vendor — 10.2 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT

5.4. Vehicles

5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.

5.5. Architectural Coatings
Phase Name Residential Interior Area
Coated (sq ft)
Residential Exterior Area
Coated (sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 0.00 0.00 546,460 181,718 2,614

5.6. Dust Mitigation

5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (Cubic
Yards)
Material Exported (Cubic
Yards)
Acres Graded (acres) Material Demolished (sq. ft.) Acres Paved (acres) Site Preparation — 87,582 2.81 0.00 —
Grading — — 6.00 0.00 —
Paving 0.00 0.00 0.00 0.00 1.00

5.6.2. Construction Earthmoving Control Strategies
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Non-applicable. No control strategies activated by user.

5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Hotel 0.00 0%
Enclosed Parking Structure 1.00 100%

5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2026 0.00 532 0.03 < 0.005
2027 0.00 532 0.03 < 0.005

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Hotel 2,090 2,047 1,487 729,218 15,182 14,873 10,805 5,297,116 Enclosed Parking
Structure

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
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0 0.00 546,460 181,718 2,614

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Hotel 4,240,891 532 0.0330 0.0040 8,788,466
Enclosed Parking Structure 350,143 532 0.0330 0.0040 0.00

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Hotel 6,341,693 0.00
Enclosed Parking Structure 0.00 0.00

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Hotel 137 —
Enclosed Parking Structure 0.00 —
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5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Hotel Household
refrigerators and/or
freezers
R-134a 1,430 0.00 0.60 0.00 1.00
Hotel Other commercial A/C
and heat pumps
R-410A 2,088 1.80 4.00 4.00 18.0
Hotel Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor

5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type
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5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 7.73 annual days of extreme heat Extreme Precipitation 7.05 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 0.30 annual hectares burned
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Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
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Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 58.2
AQ-PM 69.7
AQ-DPM 73.3
Drinking Water 49.6
Lead Risk Housing 26.7
Pesticides 0.00
Toxic Releases 74.0
Traffic 60.7
Effect Indicators —
CleanUp Sites 80.3
Groundwater 22.1
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Haz Waste Facilities/Generators 66.6
Impaired Water Bodies 0.00
Solid Waste 93.7
Sensitive Population —
Asthma 4.45
Cardio-vascular 18.3
Low Birth Weights 3.40
Socioeconomic Factor Indicators —
Education 25.9
Housing 87.0
Linguistic 87.0
Poverty 33.8
Unemployment 70.9

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 68.24072886
Employed 40.65186706
Median HI 72.46246632
Education —
Bachelor's or higher 74.51559091
High school enrollment 4.709354549
Preschool enrollment 67.02168613
Transportation —
Auto Access 11.40767355
Active commuting 55.1777236
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Social —
2-parent households 85.42281535
Voting 30.52739638
Neighborhood —
Alcohol availability 22.08392147
Park access 17.55421532
Retail density 98.83228538
Supermarket access 87.86090081
Tree canopy 61.15744899
Housing —
Homeownership 17.77235981
Housing habitability 14.69267291
Low-inc homeowner severe housing cost burden 3.464647761 Low-inc renter severe housing cost burden 49.04401386
Uncrowded housing 62.10701912
Health Outcomes —
Insured adults 74.51559091
Arthritis 0.0
Asthma ER Admissions 95.8
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 92.8
Cognitively Disabled 20.1
Physically Disabled 5.6
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Heart Attack ER Admissions 85.8
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 68.9
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors—
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures—
Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 90.2
Elderly 3.7
English Speaking 10.3
Foreign-born 93.1
Outdoor Workers 95.0
Climate Change Adaptive Capacity—
Impervious Surface Cover 17.3
Traffic Density 77.2
Traffic Access 87.4
Other Indices—
Hardship 42.9
Other Decision Support—
2016 Voting 29.1
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7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 44.0 Healthy Places Index Score for Project Location (b) 49.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Screen Justification
Land Use Lot acreage more representative for Beverly Hills, CA.

Construction: Construction Phases Removed demolition.

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Single Family Res - Beverly Hills Detailed Report
Table of Contents

1. Basic Project Information

1.1. Basic Project Information

1.2. Land Use Types

1.3. User-Selected Emission Reduction Measures by Emissions Sector

2. Emissions Summary

2.4. Operations Emissions Compared Against Thresholds

2.5. Operations Emissions by Sector, Unmitigated

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated

4.2.3. Natural Gas Emissions By Land Use - Unmitigated

4.3. Area Emissions by Source

4.3.1. Unmitigated
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 2 / 29

4.4. Water Emissions by Land Use

4.4.1. Unmitigated

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated

4.10. Soil Carbon Accumulation By Vegetation Type

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated

5. Activity Data

5.9. Operational Mobile Sources
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 3 / 29

5.9.1. Unmitigated

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated

5.10.2. Architectural Coatings

5.10.3. Landscape Equipment

5.11. Operational Energy Consumption

5.11.1. Unmitigated

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated

5.13. Operational Waste Generation

5.13.1. Unmitigated

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 4 / 29

5.16.2. Process Boilers

5.17. User Defined

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated

5.18.2. Sequestration

5.18.2.1. Unmitigated

6. Climate Risk Detailed Report

6.1. Climate Risk Summary

6.2. Initial Climate Risk Scores

6.3. Adjusted Climate Risk Scores

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores

7.2. Healthy Places Index Scores

7.3. Overall Health & Equity Scores
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7.4. Health & Equity Measures

7.5. Evaluation Scorecard

7.6. Health & Equity Custom Measures

8. User Changes to Default Data
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 6 / 29

1. Basic Project Information

1.1. Basic Project Information
Data Field Value
Project Name Single Family Res - Beverly Hills
Operational Year 2027
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.70
Precipitation (days) 19.6
Location 34.07172669672134, -118.40078196624353
County Los Angeles-South Coast
City Beverly Hills
Air District South Coast AQMD
Air Basin South Coast
TAZ 4307
EDFZ 16
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.29

1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
Single Family
Housing
150 Dwelling Unit 48.7 292,500 1,756,929 — 750 —
Parking Lot 150 Space 1.35 0.00 0.00 — — —
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1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected

2. Emissions Summary

2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 56.4 51.5 8.82 129 0.31 10.9 10.0 21.0 10.7 2.55 13.3 1,523 17,990 19,513 16.8 0.51 35.6 20,121 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 55.5 50.7 9.08 116 0.31 10.9 10.0 21.0 10.7 2.55 13.3 1,523 17,512 19,035 16.8 0.53 2.96 19,617 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 15.5 14.5 6.19 51.3 0.13 0.96 9.69 10.7 0.94 2.46 3.41 214 14,914 15,128 12.9 0.47 16.2 15,609 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 2.82 2.65 1.13 9.37 0.02 0.18 1.77 1.94 0.17 0.45 0.62 35.5 2,469 2,505 2.14 0.08 2.69 2,584

2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 5.15 4.64 3.61 42.9 0.11 0.07 10.0 10.1 0.06 2.55 2.61 — 10,909 10,909 0.49 0.41 33.5 11,078 Single Family Res - Beverly Hills Detailed Report, 7/25/2025 8 / 29
Area 51.0 46.7 3.19 84.8 0.19 10.7 — 10.7 10.5 — 10.5 1,405 2,707 4,112 4.19 0.05 — 4,232 Energy 0.24 0.12 2.02 0.86 0.01 0.16 — 0.16 0.16 — 0.16 — 4,086 4,086 0.32 0.02 — 4,098 Water — — — — — — — — — — — 10.7 288 299 1.12 0.03 — 335 Waste — — — — — — — — — — — 107 0.00 107 10.7 0.00 — 375 Refrig. — — — — — — — — — — — — — — — — 2.09 2.09
Total 56.4 51.5 8.82 129 0.31 10.9 10.0 21.0 10.7 2.55 13.3 1,523 17,990 19,513 16.8 0.51 35.6 20,121 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 5.10 4.59 3.95 39.2 0.10 0.07 10.0 10.1 0.06 2.55 2.61 — 10,454 10,454 0.50 0.43 0.87 10,596 Area 50.2 46.0 3.11 76.3 0.19 10.7 — 10.7 10.5 — 10.5 1,405 2,685 4,090 4.19 0.05 — 4,210 Energy 0.24 0.12 2.02 0.86 0.01 0.16 — 0.16 0.16 — 0.16 — 4,086 4,086 0.32 0.02 — 4,098 Water — — — — — — — — — — — 10.7 288 299 1.12 0.03 — 335 Waste — — — — — — — — — — — 107 0.00 107 10.7 0.00 — 375 Refrig. — — — — — — — — — — — — — — — — 2.09 2.09
Total 55.5 50.7 9.08 116 0.31 10.9 10.0 21.0 10.7 2.55 13.3 1,523 17,512 19,035 16.8 0.53 2.96 19,617 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 4.95 4.45 3.91 39.4 0.10 0.06 9.69 9.76 0.06 2.46 2.52 — 10,340 10,340 0.49 0.43 14.1 10,494 Area 10.3 9.97 0.27 11.1 0.01 0.74 — 0.74 0.72 — 0.72 96.2 199 296 0.29 < 0.005 — 304 Energy 0.24 0.12 2.02 0.86 0.01 0.16 — 0.16 0.16 — 0.16 — 4,086 4,086 0.32 0.02 — 4,098 Water — — — — — — — — — — — 10.7 288 299 1.12 0.03 — 335 Waste — — — — — — — — — — — 107 0.00 107 10.7 0.00 — 375 Refrig. — — — — — — — — — — — — — — — — 2.09 2.09
Total 15.5 14.5 6.19 51.3 0.13 0.96 9.69 10.7 0.94 2.46 3.41 214 14,914 15,128 12.9 0.47 16.2 15,609 Annual — — — — — — — — — — — — — — — — — —
Mobile 0.90 0.81 0.71 7.20 0.02 0.01 1.77 1.78 0.01 0.45 0.46 — 1,712 1,712 0.08 0.07 2.34 1,737 Area 1.88 1.82 0.05 2.02 < 0.005 0.13 — 0.13 0.13 — 0.13 15.9 33.0 49.0 0.05 < 0.005 — 50.3 Energy 0.04 0.02 0.37 0.16 < 0.005 0.03 — 0.03 0.03 — 0.03 — 676 676 0.05 < 0.005 — 679 Single Family Res - Beverly Hills Detailed Report, 7/25/2025 9 / 29
Water — — — — — — — — — — — 1.77 47.7 49.5 0.18 < 0.005 — 55.5 Waste — — — — — — — — — — — 17.8 0.00 17.8 1.77 0.00 — 62.1 Refrig. — — — — — — — — — — — — — — — — 0.35 0.35
Total 2.82 2.65 1.13 9.37 0.02 0.18 1.77 1.94 0.17 0.45 0.62 35.5 2,469 2,505 2.14 0.08 2.69 2,584

4. Operations Emissions Details

4.1. Mobile Emissions by Land Use

4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

5.15 4.64 3.61 42.9 0.11 0.07 10.0 10.1 0.06 2.55 2.61 — 10,909 10,909 0.49 0.41 33.5 11,078 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 5.15 4.64 3.61 42.9 0.11 0.07 10.0 10.1 0.06 2.55 2.61 — 10,909 10,909 0.49 0.41 33.5 11,078 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

5.10 4.59 3.95 39.2 0.10 0.07 10.0 10.1 0.06 2.55 2.61 — 10,454 10,454 0.50 0.43 0.87 10,596 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 5.10 4.59 3.95 39.2 0.10 0.07 10.0 10.1 0.06 2.55 2.61 — 10,454 10,454 0.50 0.43 0.87 10,596 Annual — — — — — — — — — — — — — — — — — —
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Single
Family
Housing

0.90 0.81 0.71 7.20 0.02 0.01 1.77 1.78 0.01 0.45 0.46 — 1,712 1,712 0.08 0.07 2.34 1,737 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 0.90 0.81 0.71 7.20 0.02 0.01 1.77 1.78 0.01 0.45 0.46 — 1,712 1,712 0.08 0.07 2.34 1,737

4.2. Energy

4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — 1,450 1,450 0.09 0.01 — 1,456
Parking
Lot
— — — — — — — — — — — — 75.1 75.1 < 0.005 < 0.005 — 75.4 Total — — — — — — — — — — — — 1,525 1,525 0.09 0.01 — 1,531 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — 1,450 1,450 0.09 0.01 — 1,456
Parking
Lot
— — — — — — — — — — — — 75.1 75.1 < 0.005 < 0.005 — 75.4 Total — — — — — — — — — — — — 1,525 1,525 0.09 0.01 — 1,531 Annual — — — — — — — — — — — — — — — — — —
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Single — — — — — — — — — — — — 240 240 0.01 < 0.005 — 241 Family
Housing
Parking
Lot
— — — — — — — — — — — — 12.4 12.4 < 0.005 < 0.005 — 12.5 Total — — — — — — — — — — — — 253 253 0.02 < 0.005 — 253

4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

0.24 0.12 2.02 0.86 0.01 0.16 — 0.16 0.16 — 0.16 — 2,560 2,560 0.23 < 0.005 — 2,567 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.24 0.12 2.02 0.86 0.01 0.16 — 0.16 0.16 — 0.16 — 2,560 2,560 0.23 < 0.005 — 2,567 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing

0.24 0.12 2.02 0.86 0.01 0.16 — 0.16 0.16 — 0.16 — 2,560 2,560 0.23 < 0.005 — 2,567 Parking
Lot

0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total 0.24 0.12 2.02 0.86 0.01 0.16 — 0.16 0.16 — 0.16 — 2,560 2,560 0.23 < 0.005 — 2,567 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing

0.04 0.02 0.37 0.16 < 0.005 0.03 — 0.03 0.03 — 0.03 — 424 424 0.04 < 0.005 — 425 Single Family Res - Beverly Hills Detailed Report, 7/25/2025 12 / 29
Parking 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Lot
Total 0.04 0.02 0.37 0.16 < 0.005 0.03 — 0.03 0.03 — 0.03 — 424 424 0.04 < 0.005 — 425

4.3. Area Emissions by Source

4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 43.4 39.2 3.11 76.3 0.19 10.7 — 10.7 10.5 — 10.5 1,405 2,685 4,090 4.19 0.05 — 4,210 Consum
er
Product
s

6.26 6.26 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.51 0.51 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.79 0.75 0.08 8.52 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 22.8 22.8 < 0.005 < 0.005 — 22.8 Total 51.0 46.7 3.19 84.8 0.19 10.7 — 10.7 10.5 — 10.5 1,405 2,707 4,112 4.19 0.05 — 4,232 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Hearths 43.4 39.2 3.11 76.3 0.19 10.7 — 10.7 10.5 — 10.5 1,405 2,685 4,090 4.19 0.05 — 4,210 Consum
er
Product
s

6.26 6.26 — — — — — — — — — — — — — — — —
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 13 / 29
Architect 0.51 0.51 — — — — — — — — — — — — — — — —
ural
Total 50.2 46.0 3.11 76.3 0.19 10.7 — 10.7 10.5 — 10.5 1,405 2,685 4,090 4.19 0.05 — 4,210 Annual — — — — — — — — — — — — — — — — — —
Hearths 0.54 0.49 0.04 0.95 < 0.005 0.13 — 0.13 0.13 — 0.13 15.9 30.4 46.4 0.05 < 0.005 — 47.7 Consum
er
Product
s

1.14 1.14 — — — — — — — — — — — — — — — —
Architect
ural
Coating
s

0.09 0.09 — — — — — — — — — — — — — — — —
Landsca
pe
Equipm
ent

0.10 0.09 0.01 1.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 2.58 2.58 < 0.005 < 0.005 — 2.59 Total 1.88 1.82 0.05 2.02 < 0.005 0.13 — 0.13 0.13 — 0.13 15.9 33.0 49.0 0.05 < 0.005 — 50.3

4.4. Water Emissions by Land Use

4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 10.7 288 299 1.12 0.03 — 335
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 10.7 288 299 1.12 0.03 — 335 Single Family Res - Beverly Hills Detailed Report, 7/25/2025 14 / 29
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 10.7 288 299 1.12 0.03 — 335
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 10.7 288 299 1.12 0.03 — 335 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 1.77 47.7 49.5 0.18 < 0.005 — 55.5 Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 1.77 47.7 49.5 0.18 < 0.005 — 55.5

4.5. Waste Emissions by Land Use

4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 107 0.00 107 10.7 0.00 — 375
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 107 0.00 107 10.7 0.00 — 375 Single Family Res - Beverly Hills Detailed Report, 7/25/2025 15 / 29
Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Single
Family
Housing
— — — — — — — — — — — 107 0.00 107 10.7 0.00 — 375
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 107 0.00 107 10.7 0.00 — 375 Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — 17.8 0.00 17.8 1.77 0.00 — 62.1
Parking
Lot
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 17.8 0.00 17.8 1.77 0.00 — 62.1

4.6. Refrigerant Emissions by Land Use

4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — — — — — 2.09 2.09
Total — — — — — — — — — — — — — — — — 2.09 2.09
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 16 / 29
Single — — — — — — — — — — — — — — — — 2.09 2.09
Family
Housing
Total — — — — — — — — — — — — — — — — 2.09 2.09
Annual — — — — — — — — — — — — — — — — — —
Single
Family
Housing
— — — — — — — — — — — — — — — — 0.35 0.35
Total — — — — — — — — — — — — — — — — 0.35 0.35

4.7. Offroad Emissions By Equipment Type

4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.8. Stationary Emissions By Equipment Type

4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Single Family Res - Beverly Hills Detailed Report, 7/25/2025 17 / 29
Equipm
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.9. User Defined Emissions By Equipment Type

4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipm
ent
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10. Soil Carbon Accumulation By Vegetation Type
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 18 / 29

4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetati
on
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —

4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Single Family Res - Beverly Hills Detailed Report, 7/25/2025 19 / 29
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 20 / 29
Remove — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —

5. Activity Data

5.9. Operational Mobile Sources

5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Single Family
Housing
1,416 1,431 1,283 510,661 14,008 14,156 12,687 5,051,695 Parking Lot 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

5.10. Operational Area Sources

5.10.1. Hearths

5.10.1.1. Unmitigated
Hearth Type Unmitigated (number)
Single Family Housing —
Wood Fireplaces 8
Gas Fireplaces 128
Propane Fireplaces 0
Electric Fireplaces 0
No Fireplaces 15
Conventional Wood Stoves 0
Catalytic Wood Stoves 8
Non-Catalytic Wood Stoves 8
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 21 / 29
Pellet Wood Stoves 0

5.10.2. Architectural Coatings
Residential Interior Area Coated (sq
ft)
Residential Exterior Area Coated (sq
ft)
Non-Residential Interior Area Coated
(sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
592312.5 197,438 0.00 0.00 3,528

5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250

5.11. Operational Energy Consumption

5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Single Family Housing 994,939 532 0.0330 0.0040 7,989,050 Parking Lot 51,514 532 0.0330 0.0040 0.00

5.12. Operational Water and Wastewater Consumption

5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Single Family Housing 5,591,070 30,115,797
Parking Lot 0.00 0.00
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 22 / 29

5.13. Operational Waste Generation

5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Single Family Housing 199 —
Parking Lot 0.00 —

5.14. Operational Refrigeration and Air Conditioning Equipment

5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Single Family Housing Average room A/C &
Other residential A/C
and heat pumps
R-410A 2,088 < 0.005 2.50 2.50 10.0
Single Family Housing Household
refrigerators and/or
freezers
R-134a 1,430 0.12 0.60 0.00 1.00

5.15. Operational Off-Road Equipment

5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor

5.16. Stationary Sources

5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor

5.16.2. Process Boilers
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 23 / 29
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)

5.17. User Defined
Equipment Type Fuel Type

5.18. Vegetation

5.18.1. Land Use Change

5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres

5.18.1. Biomass Cover Type

5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres

5.18.2. Sequestration

5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)

6. Climate Risk Detailed Report

6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.

Climate Hazard Result for Project Location Unit
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 24 / 29
Temperature and Extreme Heat 7.73 annual days of extreme heat Extreme Precipitation 7.05 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
Wildfire 0.30 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events. Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.

6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.

6.3. Adjusted Climate Risk Scores
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 25 / 29
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.

The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.

The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.

6.4. Climate Risk Reduction Measures

7. Health and Equity Details

7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.

Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 58.2
AQ-PM 69.7
AQ-DPM 73.3
Drinking Water 49.6
Lead Risk Housing 26.7
Pesticides 0.00
Toxic Releases 74.0
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 26 / 29
Traffic 60.7
Effect Indicators —
CleanUp Sites 80.3
Groundwater 22.1
Haz Waste Facilities/Generators 66.6
Impaired Water Bodies 0.00
Solid Waste 93.7
Sensitive Population —
Asthma 4.45
Cardio-vascular 18.3
Low Birth Weights 3.40
Socioeconomic Factor Indicators —
Education 25.9
Housing 87.0
Linguistic 87.0
Poverty 33.8
Unemployment 70.9

7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

Indicator Result for Project Census Tract
Economic —
Above Poverty 68.24072886
Employed 40.65186706
Median HI 72.46246632
Education —
Bachelor's or higher 74.51559091
High school enrollment 4.709354549
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 27 / 29
Preschool enrollment 67.02168613
Transportation —
Auto Access 11.40767355
Active commuting 55.1777236
Social —
2-parent households 85.42281535
Voting 30.52739638
Neighborhood —
Alcohol availability 22.08392147
Park access 17.55421532
Retail density 98.83228538
Supermarket access 87.86090081
Tree canopy 61.15744899
Housing —
Homeownership 17.77235981
Housing habitability 14.69267291
Low-inc homeowner severe housing cost burden 3.464647761 Low-inc renter severe housing cost burden 49.04401386
Uncrowded housing 62.10701912
Health Outcomes —
Insured adults 74.51559091
Arthritis 0.0
Asthma ER Admissions 95.8
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
Chronic Obstructive Pulmonary Disease 0.0
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 28 / 29
Diagnosed Diabetes 0.0
Life Expectancy at Birth 92.8
Cognitively Disabled 20.1
Physically Disabled 5.6
Heart Attack ER Admissions 85.8
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 68.9
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors—
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures—
Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 90.2
Elderly 3.7
English Speaking 10.3
Foreign-born 93.1
Outdoor Workers 95.0
Climate Change Adaptive Capacity—
Impervious Surface Cover 17.3
Traffic Density 77.2
Traffic Access 87.4
Other Indices—
Single Family Res - Beverly Hills Detailed Report, 7/25/2025 29 / 29
Hardship 42.9
Other Decision Support —
2016 Voting 29.1

7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 44.0 Healthy Places Index Score for Project Location (b) 49.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.

7.4. Health & Equity Measures
No Health & Equity Measures selected.

7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.

7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.

8. User Changes to Default Data
Screen Justification
Land Use Population adjusted to match that served by a 250-room hotel assuming a STR capacity of 5 people/STR and a hotel capacity of 3 people/room.