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drCAJA Environmental Services, LLC 9410 Topanga Canyon Blvd.,Suite 101 Chatsworth,CA 91311 Phone 310-469-6700 Fax 310-806-9801 (Ramboll Environmental Analysis, pp. 5-7.) The map below from Ramboll's environmental analysis shows the CalEnviroScreen map of Santa Ana's overall percentile of exposure and burden. �so bo Elko The STIR ban could shift visitor accommodations from lower-burdened, dispersed residential areas to concentrated hotel zones in southeast Santa Ana, where pollution and traffic emission levels are already elevated, leading to an increase in emissions in these communities. (Ramboll Environmental Analysis, pp. 6-7.) Construction of new hotels could further increase emissions in these areas, furthering the known pollution contributors to respiratory and cardiovascular health risks in these already overburdened communities. (Ramboll Environmental Analysis, p. 7.) The City should quantify operational impacts using the California Emissions Estimator Model (CaIEEMod) and compared against applicable operational thresholds to determine whether the operational activities would have the potential to result in exceedances of applicable daily thresholds that could subsequently cause cumulatively considerable increases in emissions of pollutants for which the region is designated as non-attainment. If operational emissions exceed the applicable daily thresholds for any criteria pollutants, mitigation measures, if feasible, would need to be provided to reduce impacts to less than significant. If feasible mitigation is not available, impacts could be significant. Construction and Operation of New Hotels Ramboll estimated the STIR ban will cause potentially significant new impacts related to hotel construction, including air quality and health impacts from construction emissions. (Ramboll Environmental Analysis, p. 11.) Ramboll concluded that construction of a hotel without emissions mitigation would result in an excess cancer risk of 48 in a million for the maximum exposed individual, exceeding by more than four times SCAQMD's threshold of 10 in a million. (Ramboll Environmental Analysis, p. 11.) The EIR must quantify the emissions generated from reasonably foreseeable construction of new hotels/motels resulting from the elimination of all STRs in the City. This analysis should be prepared using CaIEEMod and based on specific parameters for the proposed new uses being constructed (including size of the new use as well as construction schedule, construction equipment, amount of grading, amount of 14