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Santa Ana City Council November 18, 2024 Page 3 STRs help to make housing affordable for those homeowners who are able to "home share" and earn money by renting portions of their houses, or the entire house,for a period of time. This helps make homeownership possible for many Santa Ana residents who otherwise could not afford the high cost of housing. Home sharing has made communities throughout California accessible to more and more families—even if only for a weekend. It fosters vibrant and diverse communities and supports a robust tourism economy statewide. Without STRs, many desirable vacation destinations, such as Orange County, would likely be less accessible for a wide variety of families. Home sharing also addresses a critical unmet need in California's ongoing housing crisis. Aspiring full-time residents who are unable to pay steep residential move-in costs, which typically include advance payment of first and last months' rent and a sizeable security deposit, can immediately occupy an STR without the substantial up-front cost. In this way, STRs can immediately supply housing to fill a critical gap in availability facing California cities. STRs also play an important role for aspiring residents seeking to sample, and then select, the type and location of their preferred long-term rental home or home purchase. The City's complete failure to recognize the history of STRs in the City and their extensive benefits is particularly troubling. The Prohibition of STRs Will Have Significant Environmental Impacts That Have Not Been Evaluated under CEQA The Amended Ordinance will have significant environmental impacts, and the City has failed to appropriately evaluate these impacts under CEQA. As summarized next, the evidence is clear that the STR ban will impact the physical environment, resulting in reasonably foreseeable direct increases in vehicle miles traveled, air pollutants (with adverse health consequences), greenhouse gas emissions, energy use (including fossil fuels), and more. The City has fallen far short of analyzing these direct impacts in conformance with CEQA.What is more,the City patently ignores reasonably foreseeable indirect effects spurred by the STR ban, such as new construction to account for increased hotel demand, and cumulative impacts resulting from cascading regional impacts from similar STR bans. Despite our strenuous requests during the April 2024 hearings and the subsequent litigation, the City continues to shirk its responsibilities under CEQA to analyze and disclose the true consequences of its actions. 1. The City inappropriately relies on an addendum to an EIR for a completely different, unrelated project. First, the City's reliance on an addendum to the General Plan Programmatic EIR ("GP PEIR") is impermissible under CEQA because the Amended Ordinance constitutes a new project that has not been previously reviewed, and the changes it introduces are substantial, requiring new environmental review. 3