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C, 5820 Canoga Avenue, Suite 300 <br /> AINESWoodland Hills, CA 91367 <br /> T (818) 933-0200 <br /> STACEYLLP F (818) 933-0222 <br /> www.gaineslaw.com <br /> November 18, 2024 <br /> VIA EMAIL eComment(&santa-ana.org <br /> Mayor Valerie Amezcua <br /> Mayor Pro Tern Thai Viet Phan <br /> Councilmember Benjamin Vazquez <br /> Councilmember Jessie Lopez <br /> Councilmember Phil Bacerra <br /> Councilmember Johnathan Ryan Hernandez <br /> Councilmember David Penaloza <br /> Santa Ana City Council <br /> City Council Chamber <br /> 20 Civic Center Plaza M-30 <br /> Santa Ana, CA 92701 <br /> Re: November 19, 2024, City Council Meeting—Item 35: Ordinance Amendment No. 2024- <br /> 04 Repealing and Reenacting in its Entirety Article XXI to Chapter 8 of the Santa Ana <br /> Municipal Code Prohibiting Short-Term Rentals, and Adopt Enhanced Fines for <br /> Violations of the Short-Term Rentals Ordinance <br /> Dear Mayor Amezcua and Honorable City Councilmembers, <br /> This law office represents the Santa Ana Short-Term Rental Alliance ("Rental Alliance"), whose <br /> members own and operate STRs within the City. Thank you for the opportunity to submit these <br /> comments on behalf of the Rental Alliance on the City's proposed Ordinance Amendment No. <br /> 2024-04, amending the Santa Ana Municipal Code ("SAMC") to repeal and reenact a prohibition <br /> on short-term rentals ("STRs") (the "Amended Ordinance"). <br /> As we detail below, consistent with many of our prior comments, the City's proposed prohibition <br /> of STRs would (a) result in significant environmental impacts, (b) violate state and federal law, <br /> and (c) unconstitutionally infringe on the rights of hosts and their guests. We also present new <br /> evidence by technical experts demonstrating the STR ban will adversely impact the physical <br /> environment by causing reasonably foreseeable increases in vehicle miles traveled ("VMT"), air <br /> pollutants (and related adverse health consequences), greenhouse gas emissions, and fossil fuel <br /> consumption. As just one example from the attached technical reports: when comparing visitors <br /> staying at a hotel compared to an STR, mobile emissions of volatile organic compounds, nitrogen <br /> oxides("NOx"),and micro particulates("PM 2.5")—all scientifically proven to contribute to smog <br /> and increase risks of cancer,asthma,lung damage, and other health impairments—were calculated <br />