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Santa Ana City Council November 18, 2024 Page 6 Construction of new hotels without emissions mitigation would result in an excess cancer risk of 48 in a million for the maximum exposed individual— exceeding by more than 4 times SCAQMD's threshold of 10 in a million. (CAJA Report, p. 2.) • Environmental Justice Community impacts. The STR ban would disproportionately burden environmental justice communities because the City's communities most burdened by regional pollution and localized traffic exposure are located near the existing hotel stock and would be directly impacted by increased hotel usage in response to the STR ban, increasing the known pollution contributors to respiratory and cardiovascular health risks in these communities. (CAJA Report,p. 3.) • Traffic concentration and health impacts. The STR ban could increase traffic concentrated on roadways going to the hotels in the City by 7,560 vehicles per day, resulting in health impacts that would exceed the SCAQMD CEQA threshold of significance for cancer risk. (CAJA Report,p. 3.) • Energy. The STR ban would increase energy demand because hotels use more energy per person than STRs(more than 5x more electricity,more than 2x more natural gas).(CAJA Report,p. 3.)By increasing VMT,the STR ban would also increase reliance on fossil fuels to power vehicle trips—the daily mobile fuel consumption for hotels is more than five times greater for hotels compared to STRs for both gasoline and diesel—inconsistent with regional and state climate goals. (CAJA Report, p. 3.) • GHG emissions. The STR ban would result in an increase of daily mobile emissions of GHG by 443 percent,contributing to a significant increase in emissions in the area in direct conflict with regional and state goals to reduce VMT and GHG emissions from vehicle trips. (CAJA Report, p. 3.) Further, Ramboll concluded that the increased energy demand associated with hotels compared to STRs would result in a 179 percent increase in GHG emissions per person. (CAJA Report, p. 3.) • Noise.The STR ban could concentrate traffic on roadways going to hotels in the area, since many hotels in the City are located in one concentrated area of the City, resulting in noise impacts above the City's General Plan Noise Element standard of 65 dBA CNEL, potentially exacerbating existing noise impacts or creating a new significant noise impact. (CAJA, p. 4.) There are also potential indirect impacts stemming from the ban's reasonably foreseeable result of new hotel space construction. The STR ban will cause potentially significant new impacts related to hotel construction including air quality and health impacts from construction emissions including diesel particulate matter, and noise impacts exceeding the City's General Plan Noise Element standard and the City's noise ordinance. (CAJA Report p. 4.) These and the other potentially significant environmental impacts summarized in Attachment A to this letter also mean the Amended Ordinance is not eligible for a Class 1 exemption and that the City must prepare a full EIR. 6