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dFCAJA Environmental Services, LLC <br /> 9410 Topanga Canyon Blvd.,Suite 101 <br /> Chatsworth,CA 91311 <br /> Phone 310-469-6700 Fax 310-806-9801 <br /> To: Santa Ana Short-Term Rental Alliance <br /> From: Stacie Henderson, Vice President <br /> CAJA Environmental Services, LLC <br /> Date: November 14, 2024 <br /> Re: Potential Significant Environmental Effects of Banning Short-Term Rentals in the City of <br /> Santa Ana and Requirement for Additional Environmental Analysis Under CEQA <br /> Firm Background and Qualifications <br /> CAJA Environmental Services, LLC (CAJA) is an environmental consulting firm that specializes in <br /> environmental planning, research, and documentation for public and private sector clients. For over 35 <br /> years, CAJA and its predecessor company Christopher A. Joseph & Associates have offered a broad <br /> range of environmental consulting services focusing primarily on CEQA documentation for private <br /> development projects throughout California. CAJA's project experience includes environmental clearance <br /> documentation and third-party review for all types of projects including industrial, commercial, institutional, <br /> residential, mixed-use, entertainment/events, public sector, subdivisions, coastal development, and urban <br /> infill projects. Stacie Henderson is CAJA's Vice President, with 20 years of professional experience in <br /> environmental writing, planning, and research. She has contributed substantially to the preparation and <br /> management of multiple types of environmental documents pursuant to the California Environmental <br /> Quality Act (CEQA), including Environmental Impact Reports (EIRs), Mitigated Negative Declarations <br /> (MNDs), Categorical Exemptions (CEs), Sustainable Communities Project Exemptions (SCPEs), and <br /> Sustainable Communities Environmental Assessments (SCEAs). Ms. Henderson's experience comprises <br /> a variety of multi-faceted developments including single- and multi-family residential, mixed-use, <br /> entertainment, retail, institutional, commercial, industrial, and recreational developments. Ms. Henderson <br /> received a B.A. in Political Science from the University of California, Berkeley, and a law degree from <br /> Loyola Law School. <br /> Overview <br /> We understand that at its November 19th regular meeting, the City Council will consider the first reading of <br /> an ordinance to prohibit STRs in the City (the Proposed Ordinance). We further understand that the City <br /> will consider whether, based on the Addendum to the City's General Plan Update Program Environmental <br /> Impact Report ("GP PEIR"), the Proposed Ordinance requires further environmental analysis or, in the <br /> alternative, whether its adoption is categorically exempt from CEQA pursuant to a Class 1 categorical <br /> exemption for existing facilities. (CEQA Guidelines § 15301.) <br /> For the reasons summarized herein, the City's environmental analysis of the Proposed Ordinance banning <br /> all STRs in the City is inadequate. <br /> 1 <br />