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Santa Ana City Council <br /> November 18, 2024 <br /> Page 13 <br /> The City Has Refused To Provide Evidence Surrounding its Treatment of STRs and the <br /> Basis for Banning STRs in Violation of the California Public Records Act <br /> In April 2024, a Public Records Act request was filed with the City in an effort to understand what <br /> motivated the City's pursuit of a total ban on STRs. Over six months later, the City has still not <br /> produced a response to the PRA. (See PRA 24-715.) The City has responded to over 1,000 PRA <br /> requests filed after the PRA seeking information about the City's treatment of STRs. As such, the <br /> City appears to be concealing the true motivations for seeking to ban all STRs in the City. To date, <br /> the City has not provided any evidence to support its claim that STRs in the City have a negative <br /> impact on public health, safety, and welfare, if any even exists. <br /> We strongly urge the Council to refrain from taking any action on the proposed STR prohibition <br /> until the City has responded to the Public Records Act request. <br /> Proposed Path Forward <br /> We urge the City Council to rescind the currently effective and illegally adopted Ordinance,reject <br /> the Amended Ordinance, and direct Staff to work with all stakeholders to develop a new ordinance <br /> that authorizes STRs to continue operating subject to reasonable regulations. Specifically, we <br /> recommend establishing an enforcement and transient occupancy tax ("TOT") regime for STRs. <br /> This type of regulation strikes the appropriate balance while maintaining the ability of STR owners <br /> to operate in the City. <br /> While the Rental Alliance is ready and willing to work with the City, for the reasons summarized <br /> above, should the City Council move forward with adopting the Amended Ordinance we will <br /> challenge this action in court to protect our client's rights. <br /> Sincerely, <br /> GAINES & STACEY LLP <br /> atkia ic% Xm#&# <br /> By <br /> ALICIA B. BARTLEY <br /> cc: Jose Montoya (Via Email - jmontoyaksanta-ana.org) <br /> Amy Hoyt(Via Email - Amy.Hoytgbbklaw.com) <br /> Hannah Park (Via Email - Hannah.Parkkbbklaw.com) <br /> Attachments <br /> Attachment A — CAJA Environmental Services, Potential Significant Environmental <br /> Effects of Banning Short-Term Rentals in the City of Santa and Requirement Require <br /> Additional Environmental Analysis Under CEQA, November 14, 2024. <br /> 13 <br />