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Correspondence - PH #35
Ibarra, Evelyn From: Nick Valencia < Sent: Wednesday, November 13, 2024 12:06 PM To: eComment Subject: Public Comment - City Council - Nov 19th, Agenda Item #35 Attention: This email originated from outside of City of Santa Ana. Use caution wnen opening attachments or links. Dear City Council Members of Santa Ana, I am writing to express my strong support for the proposed ordinance to ban short-term rentals (STRs) in our city. The proliferation of STRs has significantly impacted Santa Ana's housing landscape, leading to profound and adverse consequences for our community. Many property owners have acquired homes solely to profit from short-term rental operations, creating a trend that undermines the integrity of our neighborhoods. While it is true that issues like noise and trash may only apply to certain properties, the broader implications of STRs are undeniable and far-reaching. Each STIR not only reduces the number of available homes but also drives up housing prices across the board. These properties are often purchased at a premium, distorting market dynamics and exacerbating the already critical shortage of affordable housing. Banning STRs would allow hundreds of homes to be reintroduced to the market, increasing the housing supply and helping to alleviate the financial strain on families who wish to make Santa Ana their permanent home. This action would represent a significant step toward fostering stability and affordability for residents, ensuring that our community remains vibrant, diverse, and sustainable. I urge you to support the ordinance banning short-term rentals and prioritize the long-term well-being of Santa Ana families over the profit -driven interests of STIR investors. Let us put the needs of residents first and work to make our city more accessible and livable for everyone. Thank you for considering this important matter. Sincerely, Nick Valencia Ibarra, Evelyn From: Martha Stewart < Sent: Wednesday, November 13, 2024 11:36 PM To: eComment Subject: Banning STRs - 35 Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. I'm reaching out as a resident of West Memory Lane, where I now find myself living next to three short-term rentals. What used to be a close-knit neighborhood has turned into a revolving door of strangers, and it no longer feels like home. The constant turnover means no familiar faces, no sense of community, and a real loss of what made our street special. Beyond the noise and occasional disturbances, the real issue is that these STRs are driving up housing costs and taking homes away from families who want to be part of Santa Ana long-term. By banning STRs, we can bring back stability and help restore the strong, connected neighborhoods that Santa Ana deserves. Thank you for considering this step to protect our community. 1 Ibarra, Evelyn From: Ana Gomez < Sent: Thursday, November 14, 2024 2:04 PM To: eComment Subject: November 19th City Council Meeting- Item 35 Attachments: Letter to City Council member November 19th meeting.docx Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Mayor Valerie Amezcua Mayor Pro Tem Thai Viet Pham Councilmember Benjamin Vazquez Councilmember Jessie Lopez Councilmember Phil Bacerra Councilmember Johnathan Ryan Hernandez Councilmember David Penaloza City Council Chamber 20 Civic Center Plaza M-30 Santa Ana, California 92701 Re: November 19th, 20241 City Council Meeting —Item 35 — Conduct a First Reading and Adopt Ordinance Amendment (OA) No. 2024-04 Repealing and Reenacting in its Entirety Article XXI to Chapter 8 of the Santa Ana Municipal Code (SAMC) Prohibiting Short -Term Rentals (STRS), and Adopt Enhanced Fines for Violation of the Short Term Rentals Ordinance I respectfully ask city council to reconsider placing a complete ban on STRs and to request that amendments, carve -outs, and or exceptions be made for on -site home - sharing short-term rental homeowners. In the ensuing months after the passage of the short-term rental ordinance in April of this year, we have had meetings/conversations (via Zoom, face to face conversations and email correspondence) with most of the city councilmembers (with exception of Councilmembers Vasquez, Bacerra and Penaloza) as well as the Mayor regarding home sharing short-term rentals. Most of the councilmembers expressed willingness to work with on site home -sharing STRs homeowners. As residents of the City of Santa Ana & on -site home -sharing STRs homeowners, we were against taking any legal action against the city and are not a party to the ongoing lawsuit filed by SASTRA. How are we different from other short-term rentals in the city? We are residents in the City of Santa Ana. We are invested in our community and city. We rent a room in our home or a granny flat/mother-in-law suite attached/detached to our primary home. We are on site during all stays and carefully vet all potential guest(s) to ensure they meet our listing rules. Furthermore, nowhere in the city staff report dated 1 November 19, 2024 does the report state how, if any, does on -site home -sharing STRs affect the City's Regional Housing Needs Allocation (RHNA). I would argue that it has little to no impact to the city's RHNA. In our situation, we rent out a room in our primary residence. We are on -site at all times. We have never had a compliant from any of our neighbors. In fact, some of our neighbors have utilized our guestroom suite when they have extended family members visiting during holidays or business associates in town for meetings. We have always maintained our property to the highest standards in order to retain the feel and charm of the neighborhood. The income derived from our STR helps us to not only maintain our home but most importantly, helps me keep my elderly father in his home. If and when the time comes that my father can no longer live on his own, then it is our plan to have him move into our guestroom suite. Eliminating STRs income would place a strain on our financial well being especially with the new administration coming in next year and the uncertainty of what is to come. We urge the city to reconsider a complete ban and work with on -site home sharing STRs homeowners. Sincerely, Ana Gomez Richard Austin Santa Ana Residents Ward 3 directed to come back with options and/or code changes (be specific on short-term rentals) on October 20, 2015. Not once during the Sept Pt or 15th city council meetings was the code ever referred to a permissive code or prescriptive code N The city council meeting on October 15, 2015, Agenda #75A extending the moratorium, was ultimately allowed to expire. Comments from councilmembers expressed support for the shared economy, they did not want to be prohibitive, restrictive or overreach. What has changed since October 2015? Nothing... study was never completed; codes were never updated to address short term rentals. Somehow between 2015 and now, the code was now being referred to as a permissive code. The code still lacks clarity as it pertains to short term rentals. If there has been a proliferation of short-term rentals, the fault lies with the planning commission. As short-term rental owners (on -site owners and responsible short term rental (`STR') owners), we actively sought to work with the planning commission. We met with the planning commission shortly after the September 26, 2022 planning commission meeting, in which code amendments were being discussed. Short term rental prohibition was on the planning commission agenda as a Zoning Ordinance Amendment No. 2022-03 (the item was ultimately taken off calendar for a later date). We proposed a STR program with regulations and supplied copies of other city guidelines to the planning commission. Again, we did not hear anything back from the planning commission. A year later, in December 11, 2023, the planning commission did ashort-term rental work study session power point presentation. Most planning commissioners were open to having a program in place and collecting TOT's (transient occupancy tax). In January 2024, some of us received an email from the planning commission requesting suggestions and/or comments on a proposed STR program in Santa Ana. We all responded within the allotted time frame for comments and/or suggestions. We felt we were finally moving forward. So, it was a surprise to all of us that over the next couple of months some the of STR owners started receiving cease and detest letters. Then in April 2024 we were taken aback by the proposed and ultimate passage of the Urgency Ordinance and the first reading of an Ordinance Amending the SAMC adding Article XXI to Chapter 8 of the SAMC Prohibiting Short Term Rentals. 3 The Urgency Ordinance contained faulty or incomplete data that may have had a different outcome on April 2, 2024. Both the Urgency Ordinance and the Ordinance state that short term rentals remove housing stock that could be otherwise available for long term rental or sale. The number of STR reported in Santa Ana is 1100. The power point presentation made in December of 2023 shows suspected 1120 rental units in Santa Ana as reported by Granicus (software solutions and information on STRs). The numbers were collected from various STR platforms. What wasn't disclosed is that one STR can be listed on 2 or more platforms, so instead of counting just 1 STR, the STR was counted twice or more. Granicus states on their website (https://support.granicus.com/s/article/Address- Identification-FAQ?lanquage=en US), under Host Compliance FAQ that "[i�t is very common for a single rental unit to be advertised across multiple listings, and as a result you will always see a higher number of listings in your jurisdiction compared to the number of rental units. " Did the reported 1100 STR units by Granicus remove duplicate listings? Complicating the numbers even more, 1 STR home renting one or more private room will be counted as two units versus one unit. The breakdown of types of STR would have been helpful as it would have given city council a better picture of the number and types of STR in Santa Ana. Over 45% of STR rentals in Santa Ana are lbd/lba unit (private rooms, guesthouses, guest suites). These types of STRs would have no impact on available housing stock. Furthermore, these types of STR have no effect on increasing rents, affordability and does not divert a significant portion of available housing away from permanent resident. Removing these types of STR from the reported 1100 STR would reduce the percentage STR has on the city's Regional Housing Needs Allocation (RHNA) for 2021-2029. Banning short term rentals will not work. Granicus talks about short term rentals bans gone wrong (https://granicus.com/blog/short-term-vacation-rental-bans- wro ). Some of the items discussed in the blog are: legality of a ban, lawsuits, loss 4 of tax revenues and spending from homeowners with greater income streams as a result of their rental income. I ask city council to reconsider the Urgency Ordinance & second reading of Ordinance. Appeal or suspend both and let's bring stakeholders back to the table to discuss a reasonable STR program regulation. Thank you Ana Gomez 5 Ibarra, Evelyn From: Abboud Khallouf < Sent: Sunday, November 17, 2024 8:18 AM To: eComment Subject: Fwd: Tuesday: Santa Ana discussing the STR prohibition Attention: This email originated from outside of City of Santa Ana. Use caution wnen opening attachments or links. Dear Sir, Madam, Following the AIRBNB email (See below please) I"'m writing today to let you know that I'm with the city's decision to prohibit the STR and if you want to replace it with another prohibition I'm also supporting this. Sincerely. Alex Khallouf ---------- Forwarded message --------- From: Airbnb Team <getinvolved@airbnb.com> Date: Sat, Nov 16, 2024 at 12:45 PM Subject: Tuesday: Santa Ana discussing the STR prohibition To: < Hi Alex, This Tuesday, November 19th, the Santa Ana City Council will hold a meeting to repeal the rushed prohibition on short- term rentals (STRs) and replace it with another prohibition. As you know, this proposal would threaten the livelihoods of hosts like you and negatively impact the small businesses that rely on STR guests. The City needs to hear from local hosts who can share how STRs support local families and the local economy. What: Santa Ana City Council and Housing Authority Meeting When: Tuesday, November 19th: 5:30pm Where: Zoom at this link OR City Council Chambers 22 Civic Center Plaza Santa Ana, CA 92701 If you can't attend the meeting in -person, you can still email the City Clerk's office at eComment(a-)-santa-ana.org. You can read the agenda here for more details. To connect with other local Hosts, you can also join the Coastal Orange County Area Airbnb Host Community group. Thanks, The Airbnb Team Click here to unsubscribe Ibarra, Evelyn From: Santa Ana Short Term Rental Alliance <sastrahosts@gmail.com> Sent: Monday, November 18, 2024 11:35 AM To: eComment Subject: Agenda Item #35 - Public Comment - (Nov. 19th) City Council Meeting Attachments: STR_Guide_Council.pdf Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Dear City Clerk, (please confirm receipt) RE: Agenda Item #35 -Public Comment -City Council Meeting (Nov. 19th) We (Santa Ana Short -Term Rental Alliance - SASTRA) have attached a PDF of our Public Comments regarding Agenda Item #35 (Short-term Rentals). We would like to request this document be shared with all Santa Ana Council members. Attached PDF: Short -Term Rental Guide (+ Letter to Council Member, page 2) Link to Download Attached SASTRA STR Guide: CLICK HERE We will also be submitting a "Request to Speak" card for the public comment periods during the November 19th meeting. Thank you for your assistance, (please confirm receipt) Jeremy LeClair, Realtor0 Santa Ana Airbnb Host DRE # 02161730 1 FINER LIVING Real Estate ------------------------------------------------- Text or Direct: (949) 510-5605 1 SANTA ANA A L L I A N C E ADVOCATING FOR REGULATION 0 Pf RMITTiNG + ENFORCEMENT Funding Affordable Housing Fostering Local Employm en t Nurturing Neighborhood Wellbeing Prepare by SASTRA for the City of Santa Ana Dear Council Members It has become clear your City Manager and City Attorney continue to provide you with misinformation, which has led to misguided decisions regarding short-term rentals (STRs). You have not been provided with the complete facts and potential repercussions of your voting decisions, which could negatively impacted thousands of families in Santa Ana. To protect our fundamental residential rights of use as homeowners, we (SASTRA) were compelled to file a lawsuit. We are holding firm and are committed to safeguarding those rights. Yet, we are also dedicated to educating you about STRs, dispelling rumors, and illustrating how permitting STRS can solve many issues this City faces. In that effort, we have created this Short -Term Rental Guide, which addresses the some of the misguided information, rumors and false statements concerning STRs. For example, your City Planning Department is claiming STRS are threatening the public health and safety and degrading neighborhoods. Yet, STRs are typically the nicest homes on the block, because we are required to maintain our properties to a higher standard for our guests. Recently, your City Planning Department claimed over 80 complaints have been received about STRS in the last year. Yet, those 80 claimed complaints are not legitimate complaints. There are a number of calls and online submissions informing the city there "is a STR in my neighborhood", which are not viable complaints. Plus, it's Not a reality that 80 separate STRs received complaints. The legitimate complaints are tied to a hand full of bad operators. Santa Ana has 1,100 STRs operating for the past decade with a 99% positive track record, because there have only been about 11 STR properties related to bad operators. You are being misled into taking action against 99% of responsible STRS homeowners who care about this city. Banning STRs, because of the 1 % of bad operators, is the true threat to public health and residential character. We'd suggest you ask your City Manager to provide you with a report of the negative economic impact that homeowners would experience; from home foreclosures, loss of employment, loss of income, loss of home values, and true neighborhood degradation as property upkeep diminishes - by banning STRs. Our STR Guide illustrates how banning STRs; has little or no impact on rent, and is not an effective tool for solving affordable housing. Plus, how new screening technology makes neighborhoods safer, and the reality of higher -income earning guests and families, that we bring into this city to contribute to the city's tourism and economic stability. ADDITIONALLY, STRS ARE YOUR SOLUTION FOR AFFORDABLE HOUSING. FOR INSTANCE, ANAHEIM, WITH ABOUT 242 PERMITTED STRS, GENERATED $5.5 MILLION LAST YEAR. SANTA ANA, WITH 1,100 STRS, COULD GENERATE OVER $15 MILLION ANNUALLY FOR OUR CITY. THIS IS NOT A HYPOTHETICAL SCENARIO; IT IS A VIABLE REALITY. We have developed a fair and effective STR Ordinance that imposes strict regulations to help you address bad operators. Current laws make it challenging to remove those who don't comply, but our proposed ordinance empowers you and your compliance teams. We are eager to collaborate with your planning department to implement a viable STR Ordinance. I urge you to direct your City Manager and Planning Department to meet with SASTRA members. Likely within 90 days, we can resolve these issues together, eliminate costly litigation, and stimulate economic growth in Santa Ana. Guide Overview Highlights 0 SASTRA (Santa Ana Short Term Rental Alliance), is dedicated to helping the City of Santa Ana developed regulation, permitting and enforcement for short-term rental operators. Which, shall add specific policies to help ensure public peace, morals, health and safety of residential neighborhoods. • Initial projections, suggest permitting our current STRs will generate $15,000,000+ in annual income for the city of Santa Ana! Thereby, providing the city the ability to allocate funds to help build affordable housing for lower income residents of Santa Ana. • Recent STR reservation screening technology is able to block bookings that are potentially higher risk for disruptive guests. SASTRA's strict regulation helps to guard against undue noise, parking issues, excess trash, parties, public alcohol or drug use and unknown transient use. • Short-term Rentals have been operating in the city of Santa Ana with close to a 99% positive track record for io+ years. s Research found that short-term rentals are not the biggest contributor to high rents, especially when it comes to the most vulnerable segments of a city's residents. 0 Cities that have restricted STRs found it was not an effective tool for solving the housing -affordability issues. • Short-term Rentals help to increase property equity, while generating curb appeal and higher standard property maintenance and upgrades. r Short-term Rentals provide employment and support for local businesses, tradesmen and domestic maintenance services. • Short-term Rentals guest generate business for local restaurants, grocery stores and tourist attractions. Recommendation A 90-day Research & Planning period, before Voting on STR You owe it to your Santa Ana house cleaners, gardeners, handyman, � pool cleaners, plumbers, electricians, contractors, Uber drivers, and � local business to ensure you are making the right decision about their livelihood and the Santa Ana families we support. Prepare by SASTRA for the City of Santa Ana Table of Contents 1 SASTRA Benefits ZShort -Term Rental Statistics 3 The Reality of Affordable Housing 4 Keeping Neighborhoods Safe 6 Community Benefits Income Potential for Santa Ana 8 STR Misconceptions 'O Recommendation (90-day Research Period) Prepare by SASTRA for the City of Santa Ana The Santa Ana Short Term Rental Affiance (SASTRA) is an unincorporated association of homeowners and hosts advocating to structure proper STR regulation, taxes, permitting and enforcement within the city of Santa Ana for the benefit of its residents and tourism. Short-term Rentals have been operating in the city of Santa Ana with close to a 99% positive track record for 10+ years. STRs provide a positive experience for the community, generating a domino effect of economic generation, increased home equity for neighborhoods and employment throughout our city. Little or No Impact on Rent There is little evidence that regulations aimed at limiting short-term rentals have successfully brought down housing costs significantly. According to independent research, the growth of Airbnb has had an extremely small impact —and in many cases, no impact at all — on rental cost increases. IENEF Non -Disruptive Guests Recent Airbnb reservation screening technology is able to block bookings that are potentially higher risk for disruptive and unauthorized parties. The tool has dramatically reduce disturbances. Additionally, in an effort to maintain income, ratings and future bookings, Hosts follow and support Airbnb"s out -right prohibition on party houses. Increase Housing Stock Initial low -end projections, suggest permitting our current STRs could generate between $ISM to $17M in annual income for the city of Santa Ana. Thereby, providing the city the option to allocate funds to help build affordable nousing for lower income residents of Santa Ana. Neighborhood Safety With over 1.4 billion all-time guest arrivals in 220+ countries and regions, Airbnb has thrived because it is built on trust. This platform allows millions of strangers to trust one another, based on screening technology and commitment, while promoting the safety and peace of mind of our communities we live, work and provide home share in. In this guide, learn key findings, true statistics and eliminate any misconceptions with Short -Term Rentals. Prepare by SASTRA for the City of Santa Ana 1 The Reality & Statistics of ShortTerm Rentals • The STR industry is largely individual homeowners. A good portion operate under small business entities for tax purposes and liability protection. • Many STR owners used their property flexibly for more than short-term stays of 30 days or less. Nearly 40% also rented for mid-term stays of 30-days to five months to host non -leisure guests like traveling nurses, hospital patients, and remote workers. • On average, STR owners relied on their STR activity for 38.1% of their income. STR owners those who own and manage multiple STRs, that reliance was even higher at an average of 56% of their income. • STR activity creates a domino effect of economic generation and jobs throughout communities. Of STR homeowners, more than 57% hired up to three contractors or service providers to service their property, and 69% spent up to $15,000 on those providers while 24% spent between $15,000 and $50,000. • The majority of STR property managers surveyed employed up to 10 full- time or part-time employees in the last 12 months and paid up to $250,000 in wages. Additionally, 61.7% of property managers hired one to 10 contractors or service providers and the majority spent up to $100,000 on these providers in the last 12 months. 0 In the past 12 months, approximately 99% reported receiving zero complaints from neighbors or members of their community about their STRs. Additionally, 99% of those with good neighbor practices in place reported positive relationships with all or most of their STRs' neighbors. • Research found that short-term rentals are not the biggest contributor to high rents, especially when it comes to the most vulnerable segments of a city's residents. cities that have restricting STRs found it was not an effective tool for solving the housing -affordability issues. Prepare by SASTRA for the City of Santa Ana The Unrealistic Affordable Housing rgument "Despite fears that Airbnb may lead to rent increases, *our research has found that short-term rentals are not the biggest contributor to high rents, especially when it comes to the most vulnerable segments of a city's residents. Put simply, restricting Ai rbn b's is not going to be an effective tool for solving the housing -affordability problems in many U.S. cities." *Harvard Business Review What Does Banning Short -Term Rentals Really Accomplish? by Sophie Calder -Wang, Chiara Farronato, and And rey Fradkin � Understanding the Reality Many city governments are interested in whether short-term rentals disproportionately affect more vulnerable segments of their population for example minorities or low- income residents. Yet, research has found that the increase in rents is more concentrated among high -income, educated, white renters and not the population City governments are, in general, concerned with. This is because short-term rentals tend to be concentrated in touristy, centrally located areas where higher -income residents live. The majority of short-term rentals are a travel luxury typically afforded by higher -income earners. These elevated properties are more expensive to rent based on their design, amenities, location and fully furnished accommodations, " If " STR homes were to transition to traditional rentals, the market monthly rent would be well above the affordability of lower -income residents. 0 an RENT Small Impact on Rental Cost According to independent research*, the growth of Airbnb has had an extremely small impact — and in many cases, no impact at all — on rental cost increases. There is also little evidence that regulations aimed at limiting short-term rentals have successfully brought down housing costs significantly. Effects of Short -Term Rentals on Local Housing Prices and Rents: A Literature Survey -� Previously Used Seasonal Housing A common fallacy is that long-term housing is being converted to STRs, thereby detracting from existing housing inventory. The study found the number of seasonal I recreational I occasional use properties closely resembles the homes listed on STR platforms, indicating that the existing STR inventory has historically been used as tourism -related lodging or was occupied part-time. This further suggests that year-round housing units are not being converted to STRs at a high rate. Rather, long-term housing inventory growth has not kept pace with STR growth. Prepare by SASTRA for the City of Santa Ana 3 Keeping Neighborhoods Safe. Traveling locals, families remodeling their home, patients coming to California for top surgeons, family reunions, youth competitions and professionals are just a few of the amazing people visiting Santa Ana. They prefer to stay in an Airbnb or VRBO location. TRUST & SAFETY With over 1.4 billion all-time guest arrivals in 220+ countries and regions, Airbnb has thrived because it is built on trust They earn and keep that trust by focusing on building a platform that allows millions of strangers to trust one another, and promoting the safety and peace of mind of our community as they live, work, travel and Host on Airbnb. A key part of this work involves partnering with cities and offering resources to help prevent and manage concerns in their community. A ban on disruptive and unauthorized parties, FIRST SAFETY to Airbnb's community disturbance policy as well as a maintained prohibition on party houses. Reservation screening technology to block certain bookings that are potentially higher risk for disruptive and SAFETY FIRST unauthorized parties, to try to reduce the risk of disruptive and unauthorized parties, as well as enhanced measures around holidays. SAFETY FIRST A 24/7 Neighborhood Support Line to give neighbors the ability to communicate directly with Airbnb, including a dedicated portal for law enforcement to submit valid legal requests for information, available in nine languages. Parties are IN THE PAST. Airbnb has taken a HEADY stance and specific actions to eliminate "parties" or any events that could disrupt neighbors or communities. STR Hosts have very strict guidelines to follow, and could receive heavy penalties or removal from the platform. STR Hosts are dedicated to maintaining their relationship, 5-star reviews, and income generated from ideal guests. Hosts have no reason to push the envelope or jeopardize their income. Prepare by SASTRA for the City of Santa Ana Guest & Host Verification Airbnb has implemented a series of initiatives and programs to further promote the safety of our consumers and community. Ongoing identity requires every booking Guest and every primary Host be verified: • Background checks in the US. As part of Ai rbn b's efforts to protect our community, we run standard criminal background checks for Hosts and Guests. • Partnering with expert organizations through our Trust and Safety Advisory Coalition (TSAC) to advise on our policies, processes, training and community education. • Secure messaging and account protection measures. We do our best to promote the online safety of our community. For example, we'll block potentially suspicious messages that contain words or numbers that might include contact information or references to other sites, including external links. • Extensive fraud and scam prevention efforts, including secure payments through our platform, specialized fraud prevention agents and 24/7 support teams to help deter scams and financial fraud. • A dedicated safety -focused Solo Traveler Safety feature to guests traveling. W1013 d NINON ■M a M 5 STRs Generate Community Benefits dKI$2\e Short-term Rentals help to increase your neighborhood equity, while generating curb appeal and better maintain properties. STR Hosts are required to maintain their properties to `labove standard'" condition, while the majority of Hosts go above and beyond to ensure their properties are attractive and well maintain, thereby increasing their guest bookings and ratings. A direct benefit to our community. Short-term Rentals provide employment and support for local businesses, tradesmen and domestic maintenance services. The majority of STR Hosts in Santa Ana employee multiple property cleaners teams, gardeners, handyman, pool cleaners, plumbers, electricians, and subcontracts on a daily or weekly basis. A direct benefit to our community. Short-term Rentals guest generate business for local TJ ' restaurants, grocery stores and tourist attractions. Our STR guests are purchasing food from local restaurants, utilizing mobile food delivery services and buying groceries at our local stores. Additionally, the majority of bookings come to Santa Ana to view and experience the multitude of tourist attractions. A direct benefit to their community. Airbnb released a report showing hosts and guests in the Los Angeles metro area contributed an estimated $4.4 billion in economic activity in 2023. Link: $4.4 Billions in Economic Activity Prepare by SASTRA for the City of Santa Ana �01 Santa Ana ANNUAL INCOME POTENTIAL There are multiple ways to capture revenue from Short -Term Rentals for the City of Santa Ana. In addition to the transient occupancy tax (TOT), business licensing, application fees, permit fees, application renewals, fire and safety checks and structured code enforcement. In most cases, the host platforms (Airbnb) are remitting transient occupancy tax directly to cities to remove the collection burden. Estimated $�5,C1AA 1,100+ STRs Business Licensing Fees V, $275,000 STR Application Fee $385,000 STR Annual Permit Fee F!7.16 557.07 559.71 Santa Ana I Low -en ID Iola ftftft iff I I I rET 'e FifqAnFaeim generated $5. SM last year from Labout 242 permitted STRs. �PERMIT V� $15,000,000 Transient Occupancy Tax Addition Income Code Enforcement ESTIMATED ANNUAL INCOME $01 3000 1 0 * low -end projection Prepare by SASTRA for the City of Santa Ana 7 Short-term Rental Misconceptions STRs are not permitted, therefore illegal in Santa Ana, (FALSE) This concept of "permissive zoning," the doctrine that "zoning ordinances prohibit any use they do not permit" has been rejected by more than one court. Le Keen v. City of Manhattan Beach, 77 Cal. App. 5th 142, 150 (2022), review denied aune 29, 2022). Plus, State in People v. Venice Suites, LLC, 71 Cal. App. 5th 715, 733 (2021). The court noting that "[a] ppl ication of the permissive zoning scheme in the manner urged by the People would lead to an absurd result where neither short-term nor long-term occupancies would be allowed an apartment House, apartment hotel, or residential building because a length of occupancy is 'not expressed."' 2 Short-term rentals increase local rental rates. (FALSE) Many city governments are interested in whether short-term rentals disproportionately affect more vulnerable segments of their population — for example minorities or low-income residents. But *our work has found that the increase in rents in New York City is more concentrated among high -income, educated, white renters and not the population city governments are, in general, concerned with. This is because short-term rentals tend to be concentrated in touristy, centrally located areas where higher -income residents live. *What Does Banning Short -Term Rentals Really Accomplish Here's a look at some U.S. cities that have restricted short-term rentals (STRs) but didn't see the hoped -far drop in long-term rental prices: • New York City: Despite cutting STRs by 80% in 2023, rental prices barely budged. Median rent slightly dropped, but average rents rose year over year, showing minimal impact. • San Francisco: Tight restrictions and mandatory host registration significantly reduced STR listings. However, rental prices remained among the nation's highest, suggesting broader economic factors play a larger role. • Santa Monica, CA: With one of the strictest STR bans, Santa Monica only permits home -sharing with the host present. Long-term rental prices stayed high, indicating that the restrictions didn't improve affordability. • Telluride, CO: The town briefly banned STRs, but after facing economic pushback, it switched to charging STR operators a fee instead. The initial ban didn't lower rents and negatively affected local businesses. 3 STRs are responsible for the rising housing costs. (FALSE) There are many factors contributing to local housing affordability challenges, from growing income inequality, to decades of exclusionary zoning, and even changing location preferences post -pandemic, including the rise of remote working from home. Where many experts agree is that the primary driver of the affordability crisis is chronic underproduction of housing. In June 2024, Santa Ana home prices were up 11.6% compared to last year. The Santa Ana housing market is expected to see continued growth in the coming years, fueled by several key factors like; Economic Expansion (A strong economy with healthy job growth), Interest Rates (low interest rates stimulate market activity and Demand Maintenance (desirable lifestyle with amenities, proximity to major cultural attractions). Prepare by SASTRA for the City of Santa Ana 8 Misconceptions continued STRs are linked to excessive noise, parking and neighborhood degradation, (FALSE) Over 11100 Short-term Rentals have been operating in the city of Santa Ana with close to a 99% positive track record for 14+ years. The city of Santa Ana has not released the details of the "complaints", but our research has found legitimate complaints are only tied to about 11 bad -operators. Airbnb reports approximately 90%+ reported receiving zero complaints from neighbors or members of their community about their STRs. Additionally, STRs with good neighbor practices in place reported positive relationships with all or most of their STRs' neighbors. STR Hosts are required to maintain their properties to "above standard" condition, while the majority of Hosts go above and beyond to ensure their properties are attractive and well maintain, thereby increasing their guest bookings and ratings. A direct benefit to their communities. 5 Banning STRs, will preserve the housing stock for long-term rentals, to help the housing crisis. (FALSE) The absurdity of taking municipal actions that limit homeowners' rights, or force the sale of a home, in an effort to generate long-term rentals for low- income residents, represents a net loss value to society. This illogical thinking will not have the desired impact, as the majority of single-family homes listed as STRs in Santa Ana were inhabited for only parts of the year by their owners. Attempting to remove the owners Home Sharing rights, will NOT likely force the home into the long-term rental market or even for sale. Rather, the home will simply return to being uninhabited for parts of the year, due to owners continued limited use requirement. 6 It is very costly and cumbersome to collect TOT. (FALSE) Since 2014, Airbnb has led the way on platform -based transient occupancy tax (TOT) collection and remittance, collecting and remitting over $7 billion to local governments around the world. Today, Airbnb collects and remits taxes in tens of thousands of jurisdictions and the number continues to grow. These taxes help fund critical public services, with many jurisdictions choosing to direct their TOT revenue to support affordable housing, tourism promotion, and economic development. 7 Structuring STIR licensing and registration is difficult. (FALSE) Simplifying the tax payment process by bringing it online is a proven way to increase compliance and ultimately benefit both citizens and staff. Companies like Gov05 can provide ordinance consultation, handle STR management and compliance, monitor online STR calendars, and help automate the entire process. Prepare by SASTRA for the City of Santa Ana 9 Recommendation 90-day nf Research Santa Ana, you'll likely need to conduct your own research, talk with your planning department, constitutes and have additional conversations with SASTRA members to address concerns. This will take time. Therefore, we suggest implementing a 90-day Research & Planning Period to ensure each of you has the information to make an educated decision. You owe i'Ot to your Santa Ana house cleaners, gardeners, handyman, pool cleaners, plumbers, electricians, contractors, Uber and food delivery drivers, and local business to ensure you are making the right 49 decision about their li41 velihood and the Santa Ana families STRs support. 0 �� 90 , DAYS, �OTE Prepare by SASTRA for the City of Santa Ana 10 (TOWN CEO=- ► J; "ALI Xf i SASTRAHosts@gmail.com 0 Gaines & Stace Y LLP [fr4Z Alicia B. Bartley, Esq. 5820 Canoga Ave., Suite 300 Woodland Hills, CA 91367 � http:// www.GainsLow.com �tp- Ibarra, Evelyn From: Tiffany Perry <tperry@gaineslaw.com> Sent: Monday, November 18, 2024 12:16 PM To: eComment Cc: Alicia Bartley; Montoya, Jose; Amy Hoyt; Hannah Park Subject: November 19, 2024, City Council Meeting — Item 35: Ordinance Amendment No. 2024-04 Attachments: Letter to Santa Ana City Council dated 11-18-24.pdf Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Mayor Amezcua and Honorable City Councilmembers, Attached please find a letter to you of today's date regarding the City Council meeting on November 19, 2024 (Item 35: Ordinance Amendment No. 2024-04). If you have any questions, please do not hesitate to contact our office. Tiffany Perry Legal Assistant Gaines & Stacey LLP 5 820 Canoga Avenue, Suite 300 Woodland Hills, CA 91367 Telephone - 818-93 3 -0200 ext. 1212 Fax - 818-933-0222 tperryggaineslaw. com website This message and any attached documents are intended only for the use of the individual or entity to which it is addressed, and may contain information that is PRIVILEGED, CONFIDENTIAL and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify us immediately by telephone or return e-mail, and return the original to us without making a copy. Thank you. 5820 Canoga Avenue, Suite 300 Woodland Hills, CA 91367 T (818) 933-0200 F (818) 933-0222 www.gaineslaw.com November 18, 2024 VIA EMAIL eCommenWsanta-ana.or Mayor Valerie Amezcua Mayor Pro Tem Thai Viet Phan Councilmember Benjamin Vazquez Councilmember Jessie Lopez Councilmember Phil B acerra Councilmember Johnathan Ryan Hernandez Councilmember David Penaloza Santa Ana City Council City Council Chamber 20 Civic Center Plaza M-30 Santa Ana, CA 92701 Re: November 19, 20241 City Council Meeting — Item 35: Ordinance Amendment No. 2024- 04 Repealing and Reenacting in its Entirety Article XXI to Chapter 8 of the Santa Ana Municipal Code Prohibiting Short -Term Rentals, and Adopt Enhanced Fines for Violations of the Short -Term Rentals Ordinance Dear Mayor Amezcua and Honorable City Councilmembers, This law office represents the Santa Ana Short -Term Rental Alliance ("Rental Alliance"), whose members own and operate STRs within the City. Thank you for the opportunity to submit these comments on behalf of the Rental Alliance on the City's proposed Ordinance Amendment No. 2024-04, amending the Santa Ana Municipal Code ("SAMC") to repeal and reenact a prohibition on short-term rentals ("STRs") (the "Amended Ordinance"). As we detail below, consistent with many of our prior comments, the City's proposed prohibition of STRs would (a) result in significant environmental impacts, (b) violate state and federal law, and (c) unconstitutionally infringe on the rights of hosts and their guests. We also present new evidence by technical experts demonstrating the STR ban will adversely impact the physical environment by causing reasonably foreseeable increases in vehicle miles traveled ("VMT"), air pollutants (and related adverse health consequences), greenhouse gas emissions, and fossil fuel consumption. As just one example from the attached technical reports: when comparing visitors staying at a hotel compared to an STR, mobile emissions of volatile organic compounds, nitrogen oxides ("NOx"), and micro particulates ("PM 2.5") all scientifically proven to contribute to smog and increase risks of cancer, asthma, lung damage, and other health impairments were calculated Santa Ana City Council November 18, 2024 Page 2 to increase by over 400%. These impacts risk harming sensitive receptors and environmental justice communities contrary to state, regional, and local policies. The City's cursory addendum is woefully inadequate in analyzing and disclosing these impacts to the community. We respectfully request that you repeal the existing Article XXI to Chapter 8 of the SMC (which was adopted illegally in April 2024) and direct Staff to work with stakeholders to develop a new ordinance that underscores that STRs may continue operating, subject to reasonable regulations, including an enforcement and transient occupancy tax ("TOT") regime for STRs. Background on the Santa Ana Short -Term Rental Alliance and Challenge to the April 2024 STR Ordinance The Santa Ana Short -Term Rental Alliance ("Rental Alliance") is an unincorporated community association made up of hardworking residents of both the City of Santa Ana and Southern California that own and/or manage homes located within City limits rented on a short-term basis. They come from diverse backgrounds and call California home. In April 2024, the City unlawfully enacted an ordinance banning STRs in the City with almost no public notice and without undertaking the environmental review required by the California Environmental Quality Act ("CEQA"). That action threatened to destroy Rental Alliance members' livelihoods and housing security, closed the door to Santa Ana for countless would-be visitors, and disproportionately affected the individuals and families most in need of flexible housing options and who are often shut out of the long-term residential housing market. In response to that illegal action, this office filed a challenge on behalf of the Rental Alliance in Orange County Superior Court (Santa Ana Short -Term Rental Alliance v. City of Santa Ana, No. TC24-5449 (Orange County Superior Court). While we are pleased that Staff has brought forward a proposal to rescind the illegally adopted ordinance, the Amended Ordinance proposes to adopt the exact same ban on STRs as adopted in April. As summarized herein, the Amended Ordinance is legally flawed, and should the City move forward with readopting the ban, the Rental Alliance intends to challenge the Amended Ordinance. History and Importance of STRs in Santa Ana STRs have always been lawful, residential uses in Santa Ana. Hosts have opened and shared their homes to transient renters for decades, providing important visitor -serving accommodations and offering guests authentic cultural experiences in all corners of the City. These rentals provide an opportunity for visitors to Orange County to meet and interact with locals who graciously share their homes. And with the exception of a brief 2015 moratorium that expired on its own terms, STRs have long been a recognized activity in Santa Ana. Indeed, many of the Rental Alliance members have acquired a business license from the City for each rental unit that they own or manage. 0) 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 Santa Ana City Council November 18, 2024 Page 4 CEQA provides that a changed project may only undergo a streamlined subsequent environmental review under certain circumstances that trigger either a subsequent EIR, a supplemental EIR, or an addendum to a previously certified EIR. (See CEQA Guidelines §§ 15162-64.) An addendum to a previously certified EIR is appropriate only when the necessary changes or additions do not trigger a subsequent or supplemental EIR, meaning the changes or additions are minor and do not involve new significant environmental effects or a substantial increase in the severity of previously identified significant effects. (CEQA Guidelines § § 15162 and 15164.) In all cases, though, CEQA's "subsequent review provisions apply only to a previously approved project that has been subject to environmental review; the provisions do not apply if the agency has proposed a new project not previously analyzed in the original environmental document." (Mantis Camp Community Association v. County of Placer (2020) 53 Ca1.App.5th 569, 606 n.26 [emphasis added]; see also Friends of College of San Mateo Gardens v. San Mateo County Community College Dist. (2016) 1 Ca1.5th 937, 950 [CEQA's "subsequent review provisions ... have no application if the agency has proposed a new project that has not previously been subject to review."].) The Staff Report asks the City to certify an addendum based on the GP PEIR that did not review the environmental impacts of the Amended Ordinance or even acknowledge the existence of STRs in the City. The Amended Ordinance therefore "has not previously been subject to review" under CEQA and the use of an addendum or any other subsequent environmental review pathway is insufficient to comply with CEQA. Further, Friends of College of San Mateo Gardens held that in order for a lead agency to rely on a previously certified CEQA document, that document must "retain informational value" as to the new project. (Friends of College of San Mateo Gardens v. San Mateo County Community College Dist. (2017) 11 Cal.App.5th 596, 605.) Here, because the GP PEIR does not analyze the impacts of banning short term rentals or even mention short term rentals at all, it retains no informational value as to the Amended Ordinance. Indeed, the GP PEIR offers no informational value on the reasonably foreseeable direct, indirect and cumulative impacts from the STR ban because the GP PEIR analysis completely ignores STRs. The Proposed Ordinance is a new project constituting a substantial change from the conditions contemplated in the GP PEIR. In a case with similar facts as this one, a court rejected the argument that a city's zoning code had always prohibited STRs and instead held that an ordinance expressly banning STRs was an amendment to the city's local coastal plan requiring Coastal Commission approval. (Keen v. City of Manhattan Beach (2022) 77 Cal.App.5th 142, 148-49.) Here, like in Keen, the Amended Ordinance does not maintain the "legal status quo" and therefore is a new project and the City cannot rely on previously approved documents that did not contemplate the impacts of the Amended Ordinance. Moreover, the environmental document prepared for the General Plan was a program EIR. "When a program EIR is employed, if a later proposal is not either the same as or within the scope of the project described in the program EIR ... it is treated as a new project and must be fully analyzed." (Save Our Access v. City of San Diego (2023) 92 Ca1.App.5th 819, 845.) [internal quotations and citations omitted].) A program EIR that does not include any discussion or analysis of a later proposed activity is not adequate to inform the public of the environmental effects of that later activity such that the later activity is outside the scope of the program EIR (Id. at 852-53.) The C! Santa Ana City Council November 18, 2024 Page 5 GP PEIR does not discuss, analyze, or inform the public of the environmental effects associated with the Amended Ordinance. Therefore, even if the City were to assess the Amended Ordinance under the GP PEIR, the environmental impacts of the STR ban were adequately assessed by the scope of the GP PEIR and therefore the STR ban must be fully analyzed with a proj ect- specific EIR. The evidence is clear and far exceeds the "fair argument" standard that an EIR is needed because the STR ban is likely to cause potentially significant impacts to the environment that were not covered by the GP PEIR. (Id. at 845 ["The Supreme Court explained `when a program EIR is employed, if a later proposal is not either the same as or within the scope of the project ... described in the program EIR,' then review of the proposal is not governed by section 21166's deferential substantial evidence standard."] [emphasis added].) In addition, even if the GP PEIR were relied upon, the high-level, programmatic nature of the GP PEIR translates to a lack of detail that requires much more than a short addendum to correct. Rather, a supplemental or subsequent EIR is needed because the STR ban cannot be addressed with "minor" changes to the GP PEIR. Under CEQA Guidelines Section 15164, an addendum is only permitted where minor changes are needed to the prior analysis. As detailed herein, the complete absence of prior analysis of STRs, let alone the STR ban, requires changes to many topic areas covered by CEQA and raises new potentially significant impacts that cannot be addressed with minor clarifications. For these reasons, the City's approval of the Amended Ordinance based on an addendum or any other subsequent, supplemental, or tiered analysis based on the GP PEIR would violate CEQA. 2. The potentially significant environmental impacts of an STR ban require the City to prepare n n P-xv F TR Even if an addendum were appropriate, the 51-page Addendum falls far short of appropriately analyzing and disclosing impacts under CEQA. The GP PEIR is silent on STRs and the Addendum contains only a cursory, superficial, and unsupported analysis of the STR ban. As detailed in Attachment A to this letter (CAJA Environmental Services, Potential Significant Environmental Effects of Banning Short -Term Rentals in the City of Santa and Requirement Require Additional Environmental Analysis Under CEQA, November 14, 2024 ["CAJA Report"]), there are several potentially significant direct environmental impacts that could result from a STR ban in the City, including but not limited to: • Air quality. The STR ban would result in an increase in daily mobile emissions of approximately 443 percent of NOx and 444 percent of PM2.5 from guests of STRs transitioning to using hotels. (CAJA Report, pp. 2-3.) NOx causes adverse health consequences including breathing difficulties and increased risk of chronic pulmonary fibrosis as well as bronchitis in children. PM2.5 can damage the respiratory tract, increasing the number and severity of asthma attacks, and aggravating bronchitis and other lung diseases, and reducing the body's ability to fight infections. (Ramboll Memo re Environmental Analysis of Short -Term Rental Regulation dated November 14, 2024, p. 3.) 5 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 Sx 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. Santa Ana City Council November 18, 2024 Page 7 If the City Council were to ignore the substantial evidence in the record of potential impacts and proceed with adopting the Amended Ordinance without first preparing an EIR to analyze these potentially significant impacts, alternatives to the STR ban that may result in lesser impacts, and mitigation measures to reduce the potential impacts, such an action would constitute an abuse of discretion. Prohibiting STRs in Santa Ana Violates State and Federal Law The prohibition of STRs in the City violates state and federal laws in numerous ways. Specifically: 1. STRs have legally operated in Santa Ana, with the City's knowledge and acceptance, for Clpr STRs have operated legally in the City for decades and the City has acknowledged the operation of STRs within its boundaries for years. For instance, on September 15, 2015, the City Council implemented "an emergency ordinance adopting a 45-day temporary moratorium on the establishment or expansion of any short term residential rental use." (Ordinance No. NS-2886.) This ordinance acknowledged that "[t]he current provisions of the Santa Ana Municipal Code [] do not clearly identify short-term residential rental uses or take into account the potential impacts associated with the establishment of STRs within existing residential zones. As such, provisions of ... the Code ... require review, study, and possible revision in order to respond to recent concerns relating to the impacts of these short-term rental uses in the City." (Id., Section 1.13 (emphasis added).) Importantly, the 2015 emergency ordinance for the moratorium specially provided: "No short-term residential rental is permitted in a residential zone as defined in Article I of Chapter 41 of the Code." (Id., Section 2.) Of course, this new prohibition would not have been necessary had STRs not been an existing lawful use in the City. On October 20, 2015, the City Council considered a recommendation to extend the moratorium adopted on September 15, 2015, but it declined to do so. The result was that STRs continued operating as lawful residential uses throughout the City. Then, after continuously issuing ministerial business licenses for hosts renting their property on a short-term basis and long after the temporary moratorium expired, the City changed its position. Around early 2022, the City suddenly claimed that STRs were prohibited based on the City's "permissive" zoning ordinance and commenced enforcement actions against existing hosts. And now, the City states in the Staff Report that "STRs are not, and have never been, a permitted use under the City's zoning code. Therefore, STRs have always been prohibited by the City and this ordinance is reaffirming existing policy and practice." (November 19, 2024, Staff Report, p. 3.) This position is directly contradicted by the Municipal Code itself. "Short -Term Rentals" are mentioned in the Municipal Code in the context of urban lot splits. The Municipal Code specifically states that "Short-term vacation rentals (STRs)" are not permitted in dwelling units on lots created by an urban lot split. (Santa Ana Mun. Code § 41.2109(1)(2); see also id. § 41- 2115(1)(2) [same prohibition for dwelling units on lot for Two -Unit Projects].) Notably, in both of these code provisions, the prohibition on STRs on these types of lots is in a separate subpart 7 Santa Ana City Council November 18, 2024 Page 8 from a prohibition on "non-residential uses" on these types of lots. (See Santa Ana Mun. Code § 41.2109(1)(1) ["Residential -only. No non-residential use is permitted on any lot created by urban lot split."]; § 41-2115(1)(2) [same].) If STRs were not a residential property use, the separate prohibition would be superfluous. The City's express prohibition of STRs on certain lots refutes the City's argument that they are prohibited by omission throughout the entire City. After all, why would the City prohibit them explicitly in one place if they were already impliedly prohibited everywhere? If they are prohibited in the entire City, sections 41-2109 and 41-2115 would be superfluous in violation of California law. (In re C.H., 53 Cal.4th 94, 102-03 (2011) [California courts strive to give meaning to every word in a statute and avoid constructions that render words, phrases, or clauses superfluous.]; Escamilla v. Vannucci, 97 Cal.App.5th 175, 187-88 (2023).) Homeowners cannot understand what is and is not prohibited if the City adopts such nonsensical readings of its own zoning provisions. Staff s position that STRs are currently unlawful under the City's current zoning ordinance is also foreclosed by the California Court of Appeal's decision in Keen v. City of Manhattan Beach. (77 Cal. App. 5th 142 (Cal. Ct. App. 2022).) There, the court considered a permissive zoning ordinance from Manhattan Beach that is very similar to Santa Ana's current zoning ordinance. Manhattan Beach's ordinance permitted "single-family residential" and "multi -family residential" uses but did not say anything about STRs. (Id. at 149.) As a result, people in Manhattan Beach had "[f]or quite some time, ... rented residential units in Manhattan Beach on both long- and short-term bases," and "[t]he City knew about that practice and occasionally got complaints about a rental property[.]" (Id. at 146.) Then, in 2015, Manhattan Beach passed an ordinance banning STRs and claimed much like Staff has done here that it was merely "reiterating" the City's supposedly existing "implicit" ban on STRs. (Ibid.) The Court of Appeal squarely disagreed, holding that Manhattan Beach's zoning code "always permitted short-term, as well as long-term, residential rentals." (Id. at 148 (emphasis added).) The court explained that once the house or apartment building was built, anyone — renter or owner — could reside there for periods long or short, since the code "offer[s] no textual basis for a temporal distinction about the duration of rentals", and the term "`residence' does not imply some minimum length of occupancy" (Id. at 148-149.) In short, "[a] `residential building' is used for human habitation without regard to length of occupancy," and "[i]t is possible to reside somewhere for a night, a week, or a lifetime." (Id. at 149.) As in Keen, the Santa Ana Municipal Code authorizes "single-family residence" and "multiple family residence" uses, and these classifications place no minimum length of occupancy restriction on these residential uses. (Santa Ana Mun. Code, § 41-184 et seq.) And, just as in Keen, long-term rental of residential property is permitted under the existing Santa Ana code. And so, just as in Keen, without any durational requirement for rentals in the code, there is no justification for the unfounded claim that STRs are currently forbidden. N6 Santa Ana City Council November 18, 2024 Page 9 2. The Amended Ordinance would unlawfully terminate existing, lawful nonconforming uses in violation of rights protected by California law and the City's Municipal Code. A lawful nonconforming use is "one that existed lawfully before a zoning restriction became effective and that is not in conformity with the ordinance when it continues thereafter." Hansen Bros. Enters., Inc. v. Bd. of Supervisors, 907 P.2d 1324, 1327 n. l (Cal. 1996) (citing cases). The nature and extent of the use at the time the use is rendered nonconforming "determines the right to continue the use." Id. California courts have long held that a party may continue to use their property even though such use is nonconforming. (Hill v. Manhattan Beach, 6 Cal.3d 279, 285-86 (Cal. 1971); Livingston Rock & Gravel Co. v. Los Angeles County, 43 Cal.2d 121, 127 (Cal. 1954); Edmonds v. Los Angeles County, 40 Cal.2d 642, 651 (Cal. 1953); E.B. Jones v. City ofLos Angeles, 211 Cal.304, 310-311 (Cal. 1930).) The reason is simple: immediate termination of previously lawful (and now non -conforming) uses would be of doubtful constitutionality. (Livingston Rock & Gravel Co., 43 Cal. 2d at 127; Edmonds, 40 Cal. 2d at 651.) This follows from "vested rights" principles, which provide that when a zoning ordinance changes, a property owner may have a "vested right" to continue the existing use, notwithstanding the newer zoning restriction. (City of Ukiah v. County of Mendocino, 196 Cal.App. 3d 47, 56-57 (Cal. Ct. App. 1987).) Santa Ana's proposed Ordinances would violate these principles. Hosts are making lawful uses of their property, and they have made significant investments in their homes to offer them as STRs. Settled California law affords them nonconforming use rights to continue their STR use. The Amended Ordinance cannot legally withdraw those rights. Prohibiting existing STRs also directly conflicts with the City's Municipal Code, which provides that legal nonconforming land uses may continue subject to limitations on expansion or enlargement of the use, or abandonment of use. (See Santa Ana Mun. Code § 41-683 — 41-689.) 3. Recent United States Supreme Court cases establish that the Amended Ordinance would result in a taking, entitling all hosts of the 700+ existing STRs in the City to compensation. The Due Process Clause of the Fourteenth Amendment safeguards rights deeply rooted in United States history. Property rights, traditionally viewed as a "bundle of sticks," are crucial to liberty, with constitutional framers emphasizing private property as bulwark against unlawful exercises of state power. The right to lease one's property is a critical aspect of these rights, protected by the Takings Clause of the U.S. and California constitutions, which requires just compensation for property taken or damaged for public use. The Supreme Court recently expanded physical takings law to encompass temporary and intermittent physical invasions similar to deprivations of the right to lease. In Cedar Point Nursery v. Hassid, the Court held that a regulation requiring agricultural employers to allow union organizers to have periodic and temporary access to farm workers on the property constituted a physical (and not a regulatory) taking. (594 U.S. at 143.) Simply put, the "regulation appropriate[d] for the enjoyment of third parties the owners' right to exclude," which, again, the Court hailed as "`one of the most treasured' rights of property ownership." (Id. at 149.) The ordinance here not only impedes on the corollary right to include, it also effectively requires hosts to allow renters I Santa Ana City Council November 18, 2024 Page 10 on their property for longer, and that longer term use amounts to a physical incursion on hosts' right to exclude. Importantly, the Federal District Court of Hawaii recently considered an ordinance similar to that proposed by Santa Ana that barred certain STRs. (Hawai'i Legal Short -Term Rental All. v. City & Crary. of Honolulu, 2022 WL 7471692, at *2-3 (D. Haw. Oct. 13, 2022).) In resolving the plaintiff's motion for a preliminary injunction, the court held that the plaintiff would likely succeed on the merits of a takings claim under the Federal and Hawaii Constitutions. (Id. at *5.) Because the Ordinance impacts both the right to include and the right to exclude from one's property, all existing STR hosts would be entitled to compensation if the City Council were to adopt the Amended Ordinance. 4. The adoption of the Amended Ordinance would constitute arbitrary and capricious decision -making. There is no evidence in the record that STRs in the City cause a nuisance, and the City's extreme approach of banning STRs and infringing on homeowners' legal rights is unsupported by the record. STRs play an important and environmentally sustainable role in the City, and provide significant benefits to the City, its residents, and its visitors, and these benefits are being completely ignored. The Staff Report provides no evidence that any STRs in the City contribute to nuisance -type conditions such as "excessive noise, parking problems, and trash," nor does it acknowledge that the SAMC already has several existing enforcement mechanisms to mitigate public nuisances. (SAMC, Chapter 17.) In reality, many STRs in the City are either owner -occupied, meaning that the host is on site while guests are present because they live there full-time and have an extra room/rooms, or are entire home STRs which are rented on a short-term basis because the owner travels or is in the City only on a seasonal basis and so cannot rent the property on a long-term basis (e.g., six-month or one- year lease). Further, as discussed in a recent study conducted by the Milken Institute on STRs in California, "the notion that decreasing STR supply will mitigate California's extreme housing shortage is not supported by the evidence. The only solution to California's housing crisis is to provide more housing: specifically denser, more affordable multifamily housing units." I A review of the Housing Element reveals that the City does not appear to mention STRs anywhere in that document. (See City of Santa Ana General Plan Housing Element). In the section of the Housing Element discussing "Housing Constraints," the City notes that various factors influencing the City's ability to meet its housing goals include market factors (land costs, construction and rehabilitation costs, availability of financing, and recent trends in foreclosures), governmental factors (land use regulations, development standards, building codes, permit procedures, and other local policies), and environmental factors (adequacy of infrastructure, public services, and water 1 Alissa Dubetz, Matt Horton, and Charlotte Kesteven, Staying Power: The Effects of Short -Term Rentals on California's Tourism Economy and Housing Affordability, MILKEN INSTITUTE (May 2022), https:Hmilkeninstitute.or,/sites/default/files/2022-05/Short Term Rentals Califomia.pdf. 10 Santa Ana City Council November 18, 2024 Page 11 supply to support new development). (Id. at A-47). Further, and as discussed in the Milken Institute study, California's decades -long housing shortage is primarily caused by failure to build enough housing due to rising construction costs, lengthy permitting times, and community opposition, which disincentivize construction of affordable housing. (Dubetz, p. 4.) As Professor Betsy Stevenson, the former Chief Economist at the U.S. Department of Labor and member of President Obama's Council of Economic Advisers, has written, banning STRs in fact undermines efforts to "make [housing] more affordable." (Betsey Stevenson, Banning Airbnb Won't Solve the Housing Crisis, BLOOMBERG NEWS (July 8, 2024), https://www.bloomberg.com/opinion/articles/2024-07- 08/banning-airbnb-will-not-make-housing-more-affordable.) To the contrary, "[a]llowing residents to rent out their homes can help them recoup some of their investment and make city living more affordable." (Ibid.) The City's conclusory approach to regulation does not meet the standard for informed, rational decision -making. Because the City lacks any justification for adopting the Amended Ordinance, such an action would be arbitrary and capricious. (Strumsky v. San Diego County Employees Retirement Assn., 11 Ca1.3d 28, 34 (1974); Avenida San Juan Partnership v. City ofSan Clemente, 201 Ca1.App.4th 1256, 1268 (2011).) 5. The adoption of the Amended Ordinance would illegally impede on hosts' right to privacy. The STR ban also implicates the "inalienable" right to privacy under the California Constitution (Hill v. NCAA, 7 Cal. 4th 1, 20 (1994)) by taking away homeowners' ability to choose who can stay in their homes. (Coalition Advocating Legal Housing Options v. City of Santa Monica, 88 Cal. App. 4th 451, 459 (2001) [explaining the "right to privacy" includes "the right to be left alone in our homes."].) These constitutional privacy protections the protect the property owner's right to host STRs and invite guests into their home. In Coalition Advocating Legal Housing Options, supra, 88 Ca1.App.4th at 454, 459, the Court of Appeal invalidated a local ordinance that limited occupants of ADUs in residential zones to the property owner, property owner's dependent, or their caregiver, finding the privacy right "to choose with whom to live in the main residence ... must apply to the right to decide who may live in the second unit [which] ... is still part of the home." Many hosts invite guests into their homes while they are present during the stay, and the City's ban on all STRs would infringe on hosts' constitutional right to privacy, which includes the right to choose who can stay In homes. The City fails to provide any substantial justification to pass the heightened scrutiny applied to laws or regulations that infringe on the right to privacy and cannot do so because STRs have no demonstrable negative impact on the City compared to other residential uses, including long-term rentals. 11 Santa Ana City Council November 18, 2024 Page 12 6. The adoption of the Amended Ordinance would illegally infringe the right to contract. The Ordinance also violates hosts' right to contract under the California constitution, which prohibits laws impairing the obligation of contracts. (Cal. Const., Art I, § 9.) The "threshold question" is "whether the state law has, in fact, operated as a substantial impairment of a contractual relationship." (Alameda Cnty. Sheriff's Ass 'n v. Alameda Cnty. Emps. ' Ret. Ass 'n, 9 Cal. 5th 1032, 1075 (2020).) "If the state law is found to create a `substantial' impairment, the inquiry turns to the means and ends of the legislation," with the state required to demonstrate a "significant and legitimate public purpose" for the law and the court required to evaluate whether the adjustment of the rights and responsibilities of the contracting parties is "reasonable" and "appropriate to th[at] public purpose." (Id. (citations omitted); see also Calfarm Ins. Co. v. Deukmejian, 48 Cal. 3d 805, 831 (1989).) Rental Alliance hosts have already agreed to rent their property on a short-term basis to guests in upcoming months. An immediate ban on STRs would invalidate those contractual obligations of STR owners in violation of this constitutional right. 7. The adoption of the Amended Ordinance would deprive hosts of their substantive due process rights. Termination of a lawful nonconforming use effects a deprivation of property without due process of law, and banning the ability of homeowners to rent their home to visitors more broadly violates their substantive due process rights under the California and U.S. constitutions by infringing on their property rights, including the "right to lease," one of the many property rights within the "bundle of sticks" of property rights. (United States v. Craft, 535 U.S. 274, 278 (2002).) 8. The proposed fines violate the United States Constitution. The administrative fines proposed by the Resolution are also so excessive as to raise federal constitutional concerns. The Eighth Amendment to the United States Constitution forbids the City from imposing excessive fines. The United States Supreme Court has held that "[t]he touchstone of the constitutional inquiry under the Excessive Fines Clause is the principle of proportionality: the amount of the forfeiture must bear some relationship to the gravity of the offense that it is designed to punish." (United States v. Bajakajian, 524 U.S. 321, 334 (1998).) Here the Amended Ordinance's proposed fines of $1,500 for a first violation, $3,000 for a second violation, and $5,000 for a third violation fail to meet the principle of proportionality. (See, e.g., Kalthoff v. Douglas Cnty., 2021 WL 3010006, at * 6 (D. Nev. July 15, 2021) (finding "it troubling that many of these fines [for violations of short-term rental ordinance] [we]re for several thousands of dollars without any authority to lower the fines for particular violators' circumstances" and enjoining enforcement of fines on constitutional grounds).) 12 Santa Ana City Council November 18, 2024 Page 13 The City Has Refused To Provide Evidence Surrounding its Treatment of STRs and the Basis for Banning STRs in Violation of the California Public Records Act In April 2024, a Public Records Act request was filed with the City in an effort to understand what motivated the City's pursuit of a total ban on STRs. Over six months later, the City has still not produced a response to the PRA. (See PRA 24-715.) The City has responded to over 1,000 PRA requests filed after the PRA seeking information about the City's treatment of STRs. As such, the City appears to be concealing the true motivations for seeking to ban all STRs in the City. To date, the City has not provided any evidence to support its claim that STRs in the City have a negative impact on public health, safety, and welfare, if any even exists. We strongly urge the Council to refrain from taking any action on the proposed STR prohibition until the City has responded to the Public Records Act request. Proposed Path Forward We urge the City Council to rescind the currently effective and illegally adopted Ordinance, reject the Amended Ordinance, and direct Staff to work with all stakeholders to develop a new ordinance that authorizes STRs to continue operating subject to reasonable regulations. Specifically, we recommend establishing an enforcement and transient occupancy tax ("TOT") regime for STRs. This type of regulation strikes the appropriate balance while maintaining the ability of STR owners to operate in the City. While the Rental Alliance is ready and willing to work with the City, for the reasons summarized above, should the City Council move forward with adopting the Amended Ordinance we will challenge this action in court to protect our client's rights. Sincerely, GAINES & STACEY LLP aveia 3% Jc3mt&# By ALICIA B. BARTLEY cc: Jose Montoya (Via Email - jmontoya(& .santa-ana.or�) Amy Hoyt (Via Email - Amy. Hovt(c�bbklaw.com) Hannah Park (Via Email - Hannah. Park c(e,bbklaw.com) Attachments Attachment A — CAJA Environmental Services, Potential Significant Environmental Effects of Banning Short -Term Rentals in the City of Santa and Requirement Require Additional Environmental Analysis Under CEQA, November 14, 2024. 13 Attachment A CAJA Environmental Services, Potential Signlificant Environmental Effects of Banning Short -Term Rentals in the City of Santa and Requirement Require Additional Environmental Analysis Under CEQA, November 14, 2024. CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 To: Santa Ana Short -Term Rental Alliance From: Stacie Henderson, Vice President CAJA Environmental Services, LLC Date: November 14, 2024 Re: Potential Significant Environmental Effects of Banning Short -Term Rentals in the City of Santa Ana and Requirement for Additional Environmental Analysis Under CEQA Firm Background and Qualifications CAJA Environmental Services, LLC (CAJA) is an environmental consulting firm that specializes in environmental planning, research, and documentation for public and private sector clients. For over 35 years, CAJA and its predecessor company Christopher A. Joseph & Associates have offered a broad range of environmental consulting services focusing primarily on CEQA documentation for private development projects throughout California. CAJA's project experience includes environmental clearance documentation and third -party review for all types of projects including industrial, commercial, institutional, residential, mixed -use, entertainment/events, public sector, subdivisions, coastal development, and urban infill projects. Stacie Henderson is CAJA's Vice President, with 20 years of professional experience in environmental writing, planning, and research. She has contributed substantially to the preparation and management of multiple types of environmental documents pursuant to the California Environmental Quality Act (CEQA), including Environmental Impact Reports (EIRs), Mitigated Negative Declarations (MNDs), Categorical Exemptions (CEs), Sustainable Communities Project Exemptions (SCPEs), and Sustainable Communities Environmental Assessments (SCEAs). Ms. Henderson's experience comprises a variety of multi -faceted developments including single- and multi -family residential, mixed -use, entertainment, retail, institutional, commercial, industrial, and recreational developments. Ms. Henderson received a B.A. in Political Science from the University of California, Berkeley, and a law degree from Loyola Law School. 0vP_rv1iP_w We understand that at its November 19t" regular meeting, the City Council will consider the first reading of an ordinance to prohibit STRs in the City (the Proposed Ordinance). We further understand that the City will consider whether, based on the Addendum to the City's General Plan Update Program Environmental Impact Report ("GP PEIR"), the Proposed Ordinance requires further environmental analysis or, in the alternative, whether its adoption is categorically exempt from CEQA pursuant to a Class 1 categorical exemption for existing facilities. (CEQA Guidelines § 15301.) For the reasons summarized herein, the City's environmental analysis of the Proposed Ordinance banning all STRs in the City is inadequate. 1 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 Reliance on an Addendum to the GP PER is Inappropriate The Proposed Ordinance is a new project, completely unrelated to the City's adoption of its General Plan, so the City's reliance on an addendum or any other subsequent, supplemental, or tiered analysis based on the GP PER would violate CEQA. The General Plan makes no reference to STRs, does not in any way evaluate existing operations of STRs, or indicate that STRs will be prohibited in the City. As a new, distinct project, it is not appropriate to prepare an addendum to an existing environmental impact report ("EIR") when that prior EIR did not previously review or even contemplate the scope of the current project or related environmental concerns, and the new project introduces changes that are substantial, requiring new environmental review. (Mantis Camp Community Association v. County of Placer (2020) 53 Cal.App.5th 569, 606 n.26 [emphasis added]; see also Friends of College of San Mateo Gardens v. San Mateo County Community College Dist. (2016) 1 Cal.5th 937, 950 [CEQA's "subsequent review provisions ... have no application if the agency has proposed a new project that has not previously been subject to review."].) Friends of College of San Mateo Gardens held that in order for a lead agency to rely on a previously certified CEQA document, that document must "retain informational value" as to the new project. (Friends of College of San Mateo Gardens v. San Mateo County Community College Dist. (2017) 11 Cal.App.5th 596, 605.) Here, because the GP PER did not mention let alone analyze STRs in any way, and certainly did not analyze the impact of banning STRs it retains no informational value as to the Proposed Ordinance. Specifically, there is no substantial evidence that the GP PER retains informational value to analyzing the Proposed Ordinance because: (1) the GP PER traffic analysis did not consider STRs and therefore provides no informational value on the STIR ban's reasonably foreseeable increases to VMT or congestion as visitors are forced to travel greater distances to regional commercial centers to find available or affordable hotels or allowed STRs; (2) the GP PER air quality and GHG analysis did not consider STRs and therefore provides no informational value on the STIR ban's reasonably foreseeable increases of air pollutants caused by the increase in VMT (and the corresponding health impacts from those pollutant increases) and increasing GHG emissions caused by the increase in VMT (and related inconsistencies with local, regional, and state climate plans); (3) the GP PER noise analysis did consider STRs and therefore provides no informational value on the STIR ban's reasonably foreseeable noise impacts caused by increased traffic congestion and construction that is reasonably foreseeable from the STIR ban; and (4) other topic areas, as documented in this letter, where the record is bereft of information pertaining to the important environmental issues that must be analyzed under CEQA to asses and disclose the environmental consequences of this action. In contrast to the GP PEIR's prior lack of analysis, our analysis below, and the technical environmental and economics reports from Ramboll Americas Engineering Solutions, Inc. ("Ramboll"), submitted concurrently with and relied upon in this report, demonstrate that there are numerous reasonably foreseeable impacts, including: • Direct impacts from the STIR ban caused by increases in VMT, air pollutants, energy use, GHG emissions, and noise: o Air Quality. Ramboll concluded that the STIR ban would result in an increase in daily mobile emissions of approximately 443 percent of NOx and 444 percent of PM2.5 from 2 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 guests of STRs transitioning to using hotels. (Ramboll Environmental Analysis, p. 4.) NOx causes adverse health consequences including breathing difficulties and increased risk of chronic pulmonary fibrosis as well as bronchitis in children. PM2.5 can damage the respiratory tract, increasing the number and severity of asthma attacks, and aggravating bronchitis and other lung diseases, and reducing the body's ability to fight infections. (Ramboll Environmental Analysis, p. 3.) Ramboll further concluded that the STIR 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 STIR ban, increasing the known pollution contributors to respiratory and cardiovascular health risks in these communities. (Ramboll Environmental Analysis, pp. 5- 7.) Ramboll concluded that the STIR 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. (Ramboll Environmental Analysis, pp. 8-9.) Further, Ramboll concluded the 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. (Ramboll Environmental Analysis, p. 11.) o GHG Emissions. Ramboll concluded that the STIR 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. (Ramboll Environmental Analysis, p. 4.) 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. (Ramboll Environmental Analysis, p. 8.) o Energy. Ramboll concluded the STIR 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). (Ramboll Environmental Analysis, pp. 7-8.) By increasing VMT, the STIR 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. (Ramboll Environmental Analysis, p. 8.) o Transportation. Ramboll concluded that the STIR ban would increase the number of trips taken by guests to and from hotels, more than doubling the trips per day compared to STRs. (Ramboll Environmental Analysis, p. 4.) As discussed herein, this increase in trips would result in air quality and health risk, GHG emissions, energy, and noise impacts. Further, Ramboll concluded the STIR ban would concentrate traffic by increasing traffic by 7,560 vehicles per day on road to the City's hotels, resulting in health risks exceeding SCAQMD3s CEQA threshold of significance for cancer risk. (Ramboll Environmental Analysis, p. 9.) 3 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 o Noise. Ramboll concluded 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. (Ramboll Environmental Analysis, pp. 9-10, 13-14.) • Indirect impacts stemming from the ban's reasonably foreseeable result of new hotel space construction. Ramboll estimates 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. (Ramboll Environmental Analysis, pp. 11-12.) • Cumulative impacts resulting from regional trends related to STR regulations that may result in potentially significant environmental impacts. These trends have potential to increase hotel occupancy rates in Orange County and the Southern California region and driveup room rates, which is particularly concerning with the upcoming 2028 Olympics. Thus, the Proposed Ordinance is a new project with new, potentially significant environmental impacts, that constitutes a substantial change from the conditions contemplated in the GP PEIR and must be subject to new environmental review under CEQA. This letter details a number of fair arguments that the STR ban may cause significant environmental impacts, requiring a new EIR. Moreover, the environmental document prepared for the General Plan was a program EIR. "When a program EIR is employed, if a later proposal is not either the same as or within the scope of the project described in the program EIR ... it is treated as a new project and must be fully analyzed." (Save Our Access v. City of San Diego (2023) 92 Cal.App.5th 819, 845.) [internal quotations and citations omitted].) A program EIR that does not include any discussion or analysis of a later proposed activity is not adequate to inform the public of the environmental effects of that later activity such that the later activity is outside the scope of the program EIR. (Id. at 852-53.) The GP PEIR does not discuss, analyze, or inform the public of the environmental effects associated with the Proposed Ordinance. Therefore, even if the City were to assess the Proposed Ordinance under the GP PEIR, it is not within the scope of the GP PEIR and must be fully analyzed as a new project under CEQA. (Id. at 845 ["The Supreme Court explained `when a program EIR is employed, if a later proposal is not either the same as or within the scope of the project ... described in the program EIR,' then review of the proposal is not governed by section 21166's deferential substantial evidence standard."]) In addition, even if the GP PEIR were relied upon, the high-level, programmatic nature of the GP PEIR translates to a lack of detail that requires much more than a 51-page addendum to correct. Rather, a supplemental or subsequent EIR would be needed because the STR ban cannot be addressed with "minor" changes to the GP PEIR. Under CEQA Guidelines Section 15164, an addendum is only permitted where minor changes are needed to the prior analysis. As detailed herein, the complete absence of prior analysis of STRs, let alone the STR ban, requires changes to many topic areas covered by CEQA and raises new potentially significant impacts that cannot be addressed with minor clarifications. 11 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 The Environmental Analysis in the Addendum is Deficient Even if an addendum were appropriate, the 51-page Addendum falls far short of appropriately analyzing and disclosing impacts under CEQA. The GP PEIR is silent on STRs and the Addendum contains only a cursory, superficial, and unsupported analysis of the STR ban. The analysis below and the technical environmental and economic analysis provided in the reports from Ramboll, submitted concurrently with this report demonstrate that there are numerous potentially significant environmental impacts that would result from an STR ban in the Proposed Ordinance. These potentially significant environmental impacts also mean the Proposed Ordinance is not eligible for a Class 1 exemption and that the City must prepare a full EIR. This is further clarified in CEQA Guidelines Section 15002(f)(1) which states: (f) Environmental Impact Reports and Negative Declarations. An Environmental Impact Report (EIR) is the public document used by the governmental agency to analyze the significant environmental effects of a proposed project, to identify alternatives, and to disclose possible ways to reduce or avoid the possible environmental damage. (1) An EIR is prepared when the public agency finds substantial evidence that the project may have a significant effect on the environment. (See: Section 15064(a)(1).) Other California jurisdictions have recognized the need to prepare an EIR when proposing STR restrictions. Earlier this year, for example, Monterey County completed an EIR for a proposed set of County regulations for STRs that restricted but did not ban STR uses in the County. An EIR is even more warranted for an ordinance proposing to ban STRs entirely. For the reasons noted below, there is substantial evidence that the City's STR ban will reasonably foreseeably result in direct and adverse changes to the physical environment including increases in VMT, air pollutants, health consequences, GHGs, and energy use as well as reasonably foreseeable indirect and cumulative impacts that may result in significant environmental effects. The City cannot rely on the GP PEIR and must prepare a new EIR. In any instance, the Addendum's superficial and conclusory analysis falls short of analyzing, disclosing, and proposing ways to mitigate these impacts and cannot be relied upon to satisfy the City's CEQA obligations. The City must prepare a new EIR, or a new Supplemental EIR to the GP PEIR, to properly analyze all areas of potential significant environmental impact, a reasonable range of alternatives to the Proposed Ordinance, and mitigation of impacts to the maximum extent feasible. 5 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 Factors Contributing to Potentially Significant Direct, Indirect, and Cumulative Environmental Effects from an STR Ban Santa Ana is the largest city in Orange County' and its central location in Orange County has long attracted tourism. As described in a leading travel advisory: Rich in authentic heritage and can't -miss gems, Santa Ana is a cultural, entertainment and culinary center of large and diverse Orange County. The city's convenient location provides easy access to all things Southern California — day trips to Los Angeles, stops at numerous nearby theme parks and stunning Pacific Ocean sunsets only found on the golden coast. But stay a while and you'll be surprised by all the art, culture and attractions only found in historic Santa Ana.2 Tourism is a cornerstone of Santa Ana's economy, driving substantial revenue and job creation for the community. As discussed in the concurrently submitted economics analysis from Ramboll, visitor spending in 2023 contributed $414.7 million to the local economy, and this spending supports local businesses and fuels sectors like food service, accommodations, retail, arts, and transportation and provides essential funding for city services like public safety, parks, and neighborhood improvements, while also alleviating the tax burden for residents. (Ramboll Economics Analysis, p. 2.) Without tourism -related tax revenue, each household would pay an additional $195 annually in local taxes. (Ramboll Economics Analysis, p. 2.) Tourism's impact on employment is equally significant, supporting nearly 3,000 jobs in Santa Ana and contributing around $137 million in wages to the local workforce. With continued growth in overnight visits and local attractions, tourism remains a vital industry that helps sustain the community's economic well- being and enhance residents' quality of life. (Ramboll Economics Analysis, p. 2.) Tourists need a place to stay. Banning STRs will force tourists to find other accommodations. The market success of STRs demonstrates that traditional hotel and motel facilities in Santa Ana are insufficient to meet the diverse needs of STR guests, including for example families for whom access to multiple bedrooms and a kitchen is the best vacation option. The reasonably foreseeable consequence of banning STRs is for tourists to find other accommodations that are less centrally located in Orange County and would thereby change tourist traffic patterns and increase VMT — or result in the impactful construction of new hotels and motels, which would result in both construction and operational impacts to the physical environment that must be evaluated under CEQA. It is reasonably foreseeable that eliminating all STRs in the City will cause the following direct, indirect, and cumulative environmental impacts: • A shift in traffic patterns resulting in increased vehicle miles traveled (VMT) due to people traveling farther distances to their vacation destinations and their temporary/transitory places of employment and residence. Both could result in significant direct environmental effects, including increased vehicle emissions, increased greenhouse gas emissions, and increased traffic congestion. I https://www.orangecounty.net/cities/SantaAna.html 2 Visit the USA, https://www.visittheusa.com/destination/santa-ana m CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 • More visitors and residents in need of temporary accommodations will rely on hotels3 which are more resource intensive than STRs by generating more energy and using more water than STRs. This has the potential to result in numerous potentially significant indirect environmental effects stemming from the increased demand for water, electricity, and natural gas, and the increased generation of wastewater and solid waste. This also has potential to impact room rates in the City, because occupancy rates in hotels are already nearly 80 percent, so room rates which are already quite high in Orange County ($209.14 average daily rate) will almost certainly increase, potentially pushing them beyond the reach of budget -conscious travelers. (Ramboll Economics Analysis, p. 4.) • Development of new hotels in the City due to occupancy restrictions, causing additional shifts in existing traffic patterns, and a wide range of other potential impacts related to hotel construction and operation. • An STR ban in the City has potential to cause a ripple effect across the region if other localities follow suit, resulting in cumulative environmental impacts from rapid elimination of STR uses, compounding issues described above including shifting traffic patterns and increased VMT, increased use of resource -intensive hotels, and development of new hotels to make up for the loss of overnight accommodations. Each of these driving factors and the potential impacts are summarized below. An STR Ban Will Result in Changed Traffic Patterns Given the already limited availability of existing hotel room nights in the City, the elimination of all STRs in the City will force visitors to and residents of the City to find transient accommodations outside of City limits. Santa Ana is a centrally located hub in Orange County with more affordable accommodations than other cities such as Laguna Beach or Newport Beach. STRs in Santa Ana facilitate affordable access to the City's cultural amenities, community attractions, and public facilities. Removing all existing STR accommodations from the City would, with certainty, change visitor traffic patterns in and around the City, as removal of STRs drives hotel rate increases 54 and visitors will either need to find accommodations farther away from Santa Ana due to the lack of availability or affordability of the limited remaining accommodations with the City. And, as further detailed below and in the reports from Ramboll, this shifting of traffic can result in a wide range of potentially significant environmental effects to air quality, GHG emissions, and transportation. 3 For simplicity, this report refers to all traditional commercial overnight accommodations, such as hotels, motels, bed and breakfasts, as "hotels." 4 For example, in NYC, one year after regulations severely restricting STRs took effect, that city's hotel rates increased 7.4 percent annually compared to a 2.1 percent nationwide average increase during the same period. PhocusWire, Airbnb takes aim at NYC a year after "failed" STIR regulations, available here: https://www.phocuswire.com/Airbnb-year-after-New-York-City-short-term-rental- regulations#:-:text=Citing%20figures%20from%20commercial%20real,even%20as%20they%20cooled%20nationw ide. (last visited Oct. 7, 2024). 7 CAJA Environmental Services, LLG 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 An STR Ban Will Increase Reliance on More Environmentally Impactful Hotels and Thereby Increase the Environmental Impacts of Tourism An STR ban will also cause more visitors and residents in need of temporary overnight accommodations to rely on hotels for those accommodations. STRs are operated out of existing homes and do not require the same intensive use of water, energy, and other environmental resources that hotels require. Ramboll concluded that the STR ban will result in increased criteria air pollutant and GHG emissions and associated health risks, increased noise impacts, increased traffic congestion, and other potentially significant environmental impacts. (See Ramboll Environmental Analysis.) Ramboll's City -specific findings are consistent with a variety of recent studies and models concerning the environmental and economic benefits of STRs. A 2018 analysis using a "Cleantech" model found that when guests stay at an STR, significantly less energy and water is used, GHG emissions are lower, and waste is reduced compared to hotel stays.5 The 2018 analysis shows that in 2017, Airbnb guests in Europe who stayed at an STR instead of a hotel achieved energy savings equal to that of 826,000 homes and reduced water usage equal to 13,000 Olympic -sized swimming pools.6 Airbnb guest stays in North America resulted in lower GHG emissions equal to that of over 354,000 cars and waste reduction of 64,000 tons compared to hotel stays.? An article published in the Small Business Institute Journal also proposed that sharing economy based accommodations are likely to consume less energy and water, and produce fewer GHG emissions and less waste, than traditional accommodations.$ Further, the "Trip Generation Model" prepared by International Transportation Engineers (ITE),' confirms that a residential home generates less traffic than a hotel. In addition, a 2020 report regarding STRs along the California coast found that "The sharing economy can compete with hotels by offering a different sort of service with a unique structure. STRs pop up throughout cities where there is demand for lodging. They do not require centralization or maintaining inventory, which helps lower costs ... Rentals offer a more sustainable option that requires fewer resources and helps increase access with more diverse accommodation options and better value.9910 For all these reasons, the transition of STR guests to hotel guests has the potential to result in increased demand for water, electricity, and natural gas, and the increased generation of GHG emissions, wastewater and solid waste, and increased traffic. And, as further detailed below, this can result in a wide range of potentially significant environmental effects to air quality, energy, GHG emissions, land use and planning, noise, public services, transportation, and utilities. 5 Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide. 6 Ibid. 7 Ibid. 8 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, pp. 61- 63 (2017). 9 ITE, Trip Generation Manual, 11th Ed. (TripGen11), available for purchase here: https://www.ite.org/technical- resou rces/topics/tri p-and-parki ng- generation/#:-:text=The%201TE%20Trip%20Generation%20Manual%20presents%20a%20summary%20of%20the ,to%20the%20Trip%20Generation%20Manual. 11 King and Jenkins, Unequal Access: Protecting Affordable Accommodations Along the California Coast (2020). 8 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 It is Reasonably Foreseeable an STR Ban Will Spur New Hotel Development and the City Must Analyze Associated Impacts The City has reported there are over 700 existing STRs in the City (Staff Report, p. 2). Ramboll has determined there are approximately 1,000. (Ramboll Environmental Analysis, p. 1.) Banning all of these overnight accommodations would translate to the loss of a significant number of overnight accommodation nights in the City. The City's existing commercial overnight accommodation market (hotel/motel/bed and breakfast, etc.) simply cannot absorb the loss of overnight accommodation nights caused by the elimination of the STR market, given the already high occupancy rate of Orange County overnight accommodations. (See Ramboll Economics Analysis, pp. 2-4.) Yet the Addendum makes no mention of the foreseeable development of new hotels that would result from eliminating all existing STRs in the City, a fatal flaw in that analysis which discredits every impact conclusion that the Addendum reaches. As reported by Matthews Real Estate Investment Services in 2023: Hotel occupancy in Orange County is above the national average. Demand for O.C. rooms is still high despite rising rates, as the region is a hot spot for tourism, leisure travel, and business. An increase in business travel demand was generated by tech, financial, BioMed, and medical supply companies implementing large group visiting over the last few quarters." Hotel Valuation Index also reported in 2023: The Anaheim -Santa Ana hotel market spans the entirety of Orange County, which supports a diverse base of economic industries and sectors, including technology, finance, manufacturing, education, and healthcare, among others. Orange County's hotel submarkets include Orange, Garden Grove, Anaheim (which features the Disney theme parks), Buena Park (home of Knott's Berry Farm), Irvine (home to University of California Irvine's campus and numerous corporate headquarters), and the affluent coastal communities of Dana Point, Huntington Beach, Laguna Beach, and Newport Beach. In 2023, occupancy for this market surpassed 70.0%. Major factors driving the 2023 performance level included the rebound of amusement park attendance, the return of major conventions, and the gradual recovery of corporate travel.12 Given the robust Orange County overnight accommodations market, it is reasonably foreseeable that the City's ban on STRs will drive the development of new hotels, the impact of which the City must analyze in an EIR. (See Ramboll Economics Analysis, pp. 2-4.) 11 Matthews Real Estate Investment Services, Hospitality Market Report I Southern California (Feb. 2023) available here: https://www.matthews.com/hospitality-market-report-socal (last visited Oct. 7, 2024). 12 HVS, Hotel Valuation Index — United States — Anaheim -Santa Ana, available here: https://hvi.hvs.com/market/united-states/Anaheim - Santa Ana (last visited Oct. 7, 2024). 0 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 The City already has a plan in place to accommodate new hotel development. In 2016, the City adopted a hotel incentive program aimed at attracting new hotel development,13 spurred by an increase in tourism in Orange County, and Santa Ana's proximity to hubs of tourism including Anaheim's resort district, the John Wayne Airport, and local amenities including the Discovery Cube Orange County and the Bowers Museum.14 The City's General Plan has identified certain locations appropriate for the development of hotels including in the land use designations District Center — Medium and Industrial/Flex (at Brookhollow Specific Development (SD) Plan No. 8), specifically at 55 Freeway and Dyer Road.15 The City's Harbor Mix Use Transit Corridor Plan notes it could lead to the addition of new hotels.16 In addition, the City's Midtown Specific Plan and Metro East Mixed -Use Overlay District Expansion and Elan Development Projects each specifically contemplates new hotels.17 Further, hotel and motels are also permitted to be constructed and operated in C-1, C1-MD, C2, C4, C5, CR, and CSM Zoning Districts. As the City has identified specific areas where hotels could be developed, the City is capable of conducting meaningful and informational environmental review of the hotels' construction now. In 2016, the City noted that the average occupancy of Orange County hotels was at 78 percent, spurring the need for new hotel development in the area.18 As discussed in the Ramboll report, hotel occupancy rates in Orange County as of September 2024 are 77 percent. (Ramboll Economics Analysis, p. 2.) Evidence from Ramboll shows that removal of all existing STRs which are a "significant portion of the lodging market" would leave a "considerable gap in available accommodations, which the existing hotel infrastructure is unlikely to be able to fully absorb." (Ramboll Economics Analysis, pp. 3-4.) The City must evaluate this evidence to understand the current demand for hotels and STRs, and project the demand that would result from a ban on all STRs in the City. In the absence of all STRs, it is reasonably foreseeable that market forces will drive new hotel development to replace the loss of nights from the STR market. It is also reasonably foreseeable that the construction of new hotels in the City will result in a wide range of potential environmental effects to air quality, biological resources, cultural and tribal cultural resources, energy, GHG emissions, hazards and hazardous materials, land use and planning, noise and vibration, public services, transportation, and utilities. The City Must Consider Cumulative Regional Impacts of STR Bans An STR ban in the City has potential to cause a ripple effect across the region if other localities follow suit, resulting in cumulative environmental impacts from rapid elimination of STR uses, compounding issues described above including shifting traffic patterns and increased VMT, increased use of resource -intensive 13 City of Santa Ana, Hotel Incentive Program, available here: https://www.santa-ana.org/hotel-incentive-program (last visited Oct. 7, 2024). 14 City Council Staff Report, June 7, 2016, Hotel Development Incentive Program, available here: https://publicdocs.santa-ana.org/WebLink/DocView.aspx?dbid=1 &id=88417&page=1 &cr=1. 15 Santa Ana General Plan, Land Use Element, LU 56-58. 16 City of Santa Ana, Harbor Mixed Use Transit Corridor Specific Plan, pp. 1-2 (Oct. 2014). 17 City of Santa Ana, Midtown Specific Plan, pp. 29, 38 (Dec. 1996); Metro East Mixed -Use Overlay District Expansion and Elan Development Projects Subsequent EIR, p. 3-39 (June 2018). 18 City Council Staff Report, June 7, 2016, Hotel Development Incentive Program, available here: https://publicdocs.santa-ana.org/WebLink/DocView.aspx?dbid=1 &id=88417&page=1 &cr=1. 10 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 hotels, and development of new hotels to make up for the loss of overnight accommodations. The City must evaluate these potential cumulative impacts. Impact Analysis The below describes and evaluates several potentially significant adverse environmental impacts that will or are reasonably likely to occur as a result of a ban of STRs in the City. This analysis is supplemented by technical reports prepared by Ramboll which provide further analysis related to air quality, energy, greenhouse gas, land use and planning, noise and vibration, and transportation impacts. The Addendum fails to account for any of these potential impacts, entirely ignoring the foreseeable impacts resulting from elimination of all STRs in the City discussed above. This is a fatal flaw, and the City must prepare an Environmental Impact Report to evaluate the STR ban. Project Description The description of the STR ban in the Addendum does not meet CEQA's requirements for an adequate project description. Under CEQA, "[a]n accurate and complete project description is necessary for an intelligent evaluation of the potential environmental impacts of the agency's action. (City of Redlands v. County of San Bernardino (2002) 96 Cal.App.4t" 398, 405.) "If the description is inadequate because it fails to discuss the complete project, the environmental analysis will probably reflect the same mistake." (Dry Creek Citizens Coalition v. County of Tulare (1999) 70 Cal .App.4t" 20, 31, 32. ) The Addendum describes the "project' as an ordinance "to expressly prohibit short-term rentals within the city", claiming that the existing Municipal Code "does not and has never listed short-term rentals as a permissible use in any zoning district. As such STRs are prohibited and unauthorized..." (Staff Report, Attachment 3, p. 13.) The City fails to accurately describe the project. As discussed in greater detail in the legal analysis submitted by the Santa Ana Short -Term Rental Alliance, the City's position that STRs are illegal and have never been permitted in the City is incorrect. STRs are existing, lawful residential uses of property that have been operating in the City for decades. The ordinance, therefore, is not reaffirming existing law, but imposing a new prohibition on short-term rentals and eliminating all existing, legal short-term rentals. Mitigation Measures As discussed above, reliance on an Addendum to the GP PEIR is inappropriate because the Proposed Ordinance is a different project from the City's General Plan and environmental analysis of the Proposed Ordinance thus cannot be accomplished through an addendum. It follows that the City would be unable to rely on the mitigation measures from the GP PEIR to mitigate the potentially significant environmental impacts described herein to less than significant. Instead, the City must prepare an EIR for the Proposed Ordinance with mitigation measures designed to address any significant impacts. 11 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 Air Quality Overview As discussed in greater detail in the technical environmental report from Ramboll, an STR ban is reasonably likely to significantly impact air quality in several ways, including adverse impacts due to increased VMT of visitors traveling longer distances to reach travel destinations, and from the reasonably foreseeable construction and operation of new hotels to accommodate patrons who would have previously utilized STRs. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance "would not result in any physical impacts on the environment or impacts associated with air quality," and that there would be no change in air quality impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 21.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of air quality impacts is insufficient, finding that that increases in air quality impacts "are based on construction of new structures generating new vehicle trips or population growth." Since the Proposed Ordinance "would only affect existing structures [and] would not induce population growth," there would be no change in air quality impacts beyond those identified in the GP PEIR, and therefore no impacts would occur with respect to air quality. (Staff Report, Exhibit 3, p. 21.) This analysis is entirely superficial, lacking any consideration of the reasonably foreseeable impacts of an STR ban including increased VMT, increased criteria air emissions from hotels within and outside of the City, and construction of new hotels. Air quality impacts are a significant concern for local and state policymakers and agencies. The Conservation Element of the City's General Plan provides that the City should "[p]rotect air resources, improve regional and local air quality, and minimize the impacts of climate change."19 Further, as detailed in the technical environmental report from Ramboll, the STR ban will disproportionately burden environmental justice communities given the City's existing pollution burdens from regional pollution and localized traffic exposure near existing hotel stock, and the potential for increased hotel usage in response to the STR ban. Increased VMT An STR ban is likely to displace a substantial number of existing travelers from overnight accommodations located in closer proximity to travel destinations and residents staying in temporary overnight accommodations located in closer proximity to schools and places of employment. Many families who seek overnight accommodations prefer to stay in STRs for a variety of reasons, since STRs can meet more specialized accommodation needs compared to hotels. Visitors and residents who choose to stay in STRs in other, less regulated areas of Southern California will then have to drive greater distances, consume more energy, and increase criteria air emissions. 19 Santa Ana General Plan, Conservation Element, CN-05. 12 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 Ramboll's analysis concluded that increased travel to and from hotels and STRs in the region because of the unavailability of STR in Santa Ana could "considerably increase" mobile emissions in the area relative to South Coast AQMD (SCAQIVID) thresholds for criteria air pollutants, with the potential to cause short- term and long-term health impacts to sensitive receptors, exceedances of appliable air quality standards, and inconsistencies with applicable air quality and climate plans, all of which create a fair argument of environmental impacts that need to be studied further under CEQA. (Ramboll Environmental Analysis, p. 4.) Specifically, Ramboll concluded that the STR ban would result in an increase in daily mobile emissions of approximately 443 percent of NOx and 444 percent of PM2.5 from guests of STRs transitioning to using hotels. (Ramboll Environmental Analysis, p. 4.) NOx causes adverse health consequences including breathing difficulties and increased risk of chronic pulmonary fibrosis as well as bronchitis in children. PM2.5 can damage the respiratory tract, increasing the number and severity of asthma attacks, and aggravating bronchitis and other lung diseases, and reducing the body's ability to fight infections. (Ramboll Environmental Analysis, p. 3.) Ramboll further concluded that 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. (Ramboll Environmental Analysis, pp. 5-7.) In addition, Ramboll concluded that the STR ban could increase traffic concentrated on roadways going to the hotels in the City, increasing traffic by 7,560 vehicles per day, resulting in health impacts that would exceed the SCAQMD CEQA threshold of significance for cancer risk. (Ramboll Environmental Analysis, pp. 8-9.) The City's further analysis of air quality impacts from the STR ban should be supported with a technical study prepared by a qualified air emission expert with significant air quality impact model experience because the analysis of criteria pollutant generation relative to applicable health, safety, and emission regulations is highly technical and relies on specialized models. The City must also find that the STR ban is consistent with local air quality plans and the Regional Air Quality Strategy and, if not, provide mitigation. Increased Criteria Air Emissions from Hotels in City and Outside City When guests stay at an STR, significantly less energy is used, and GHG emissions are lower compared to hotel stays.20 As discussed above, Ramboll concluded that the STR ban would increase reliance on hotels, resulting in an increase in mobile emissions of criteria air pollutants up to 444 percent compared to STRs, increasing health risks and cancer risk. (See Ramboll Environmental Analysis, pp. 3-9.) Increased criteria air emissions will also disproportionately burden environmental justice communities. (See Ramboll Environmental Analysis, pp. 5-7.) The CalEnviroScreen tool identifies the City and particularly the freeway -adjacent tracts as highly burdened, being classified into the 80th percentile and above. Communities adjacent to freeways ranked in the 901" percentile and above, facing an extreme burden from air pollution associated with vehicle traffic emissions and direct traffic exposure. 21 Airbnb, Airbnb: Helping travel grow greener, p. 3 (Mar. 2017); Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 2017 SMALL BUSINESS INST. J. 13.2, pp. 61-63. 13 CAJA 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 Is environmental analysis shows the CalEnviroScreen map of Santa Ana's overall percentile of exposure and burden. sodium - oranan®gym Overall Percentile x 0 CaEnvirGScreen 4.0 Results u i w' >90 - 100 (Highest Scores.) chapmanAv Drange Mad '' Chapman Ave I l' ce t rt Almard Avh - - ■ >SO 99 w.dstm S'4 z70 90 Lampsrn A. L Rai Ld� � �� ■ don Grave Garden Grove � �zl--.�—.��eaeh.crrn�'f"'y� � Leo 70 m o F.irh MemorLA >40 50 ©' Fa rk TI.ISk A:E �Cra m L =.anti Clara A4'E �Gaiden.Grpve•Ewy z � ■ >3040 x a en rol LL ■ r20-30 hla rke 1pla� 'i P• 171h St - Inr .ter Ave zy" ` sans An c ��-�a�t �^m ■ >10 20 j c College v.Rn,'f. '- z � i. -- ■ 0 10 [Lowest Scoresj d ';r Hazard As•E' rllco r� a CIVIC CEnter Dr :f; �. "IFitl .� .. Frh S[ ii sanl.iA'- G'Ivd J"anti Ana -E - kve : .-.__.._—______ W I t— - - -'- 55• TuSfin .P PI m IN hx Fadden Ave _ n - - m E Mi,F,r6 Fy 'rd L crAi'e •• I •"! :.'1 TliStln :� GoIfC ea - 'r'ea1 �"� Mue square r `filly .r E Edinger A'e Fegonal Far; Mile ea r . .I An:r:.,.-,•; ❑I Regr Sq are F'a rk A Golf Couru ,W, A. e _-. _ v' _W W't nII Ave - ����_ �a•9 `� �•n F I111t:dn H n F a is --7 1 _ x � I.br I I.Ave r. ih ❑Isia 1� v � � at tin In —ndicii,rAve v Plae �Anton1 Gisler A•:� 1-405-H0% Ln nA E 4p vlllr C L'erde Country `- F Club _.. LL Eaker cl hn ` ] Ca1. yj eb LI -ne fi.on le [r „ - Orange 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 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 hauling, etc.). The results should then be compared to the applicable regional and localized significance thresholds to determine whether the construction 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 regional or localized construction 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. As described above, the City's General Plan, various Specific Plans, and Zoning Code have identified certain locations in the City appropriate for hotels. Depending on the availability of land to construct these new hotels in these identified areas, it is possible that they would be constructed farther from a city center or tourist destinations, resulting in greater urban sprawl and vehicle miles traveled (VIVIT). The City failed to analyze whether the reasonably foreseeable construction of new hotels as a result of an STR ban may be inconsistent with growth projections in the applicable regional air quality plan or result in emissions that exceed thresholds. The City also failed to study whether construction of new hotels in the areas identified in the General Plan may have adverse impacts on environmental justice areas, where pursuant to Policy CN-1.5 of the Conservation Element of the General Plan, the City should "[s]tudy the impacts of stationary and non -stationary emission sources on existing and proposed sensitive uses and opportunities to minimize health and safety risks" and "[d]evelop and adopt new regulations avoiding the siting of facilities that potentially emit increased pollution near sensitive receptors within environmental justice area boundaries.3321 The City must conduct this analysis in an EIR to understand all potential air quality impacts of an STR ban. Air Quality Mitigation Measures from the GP PEIR are Inadequate The City cannot rely on the air quality mitigation measures from the GP PEIR to address these potentially significant air quality impacts because, as discussed above, the Proposed Ordinance is a separate project and cannot be addressed through an Addendum to the GP PEIR and, therefore, the mitigation measures from the GP PEIR cannot be applied to this new project. Moreover, the air quality mitigation measures from the GP PEIR would not provide adequate mitigation for the impacts described above, such as increased VMT from elimination of STRs, since the air quality mitigation measures are primarily aimed at construction impacts and site -specific developments. (See Staff Report, Exhibit 3, pp. 18-19.) Biological Resources Overview An STR ban may significantly impact biological resources from the reasonably foreseeable construction of new hotels to accommodate patrons who would have previously utilized STRs. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in biological 21 Santa Ana General Plan, Conservation Element, CN-05. 15 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 resources impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 23.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of biological resources impacts is insufficient, finding that the STR ban would "only affect existing structures," and "is not anticipated to result in physical impacts to the environment." (Staff Report, Exhibit 3, p. 23.) This analysis lacks any consideration of the reasonably foreseeable construction of new hotels from an STR ban, which could result in potentially significant impacts to biological resources. Construction of New Hotels Direct impacts to biological resources may occur if new hotels are constructed on land that contains protected species, wetlands, jurisdictional waters, special status plant or animal communities, species migration corridors (including migratory birds), and habitat conservation areas. As discussed above, the City's General Plan, various Specific Plans, and Zoning Code have identified certain locations in the City appropriate for hotels. The City has not evaluated the potential for these areas to have protected habitat, so it is unknown whether development in these areas would fragment key habitat, for example, or otherwise interfere with special status plant or animal communities. This needs to be evaluated in a full EIR. The Conservation Element of the City's General Plan identifies as Goal CN-2: Natural resources, the goal of preserving and enhancing "Santa Ana's natural and environmental resources while maintaining a balance between recreation, habitat, restoration and scenic resources.9922 Policy CN-2.1 is aimed at preservation of biodiversity and provides for collaboration "with State and County agencies to promote biodiversity and protect sensitive biological resources.9923 Failure to analyze the potential impacts to biodiversity from construction of new hotels is inconsistent with the City's General Plan. The construction and operation of new hotels in locations that physically and directly affect these resources by, for example, removing habitat such as trees, or that have substantial indirect effects, such as dust, noise and vibration, light, trash, vehicle use, and other anthropogenic activities in close proximity with high - value habitats or migration routes, would have significant impacts and require the imposition of all feasible mitigation under CEQA. The City failed to analyze whether development of new hotels may occur on any such lands, and if so, what mitigation measures, if feasible, would need to be provided to reduce impacts to less than significant. Absent any feasible mitigation, impacts to biological resources could be significant. Cultural Resources Overview An STR ban may significantly impact cultural resources from the reasonably foreseeable construction and operation of new hotels to accommodate patrons who would have previously utilized STRs. Cultural resources including historical resources, archaeological resources, and human remains, could be 22 Santa Ana General Plan, Conservation Element, CN-09. 23 Ibid. CAJA Environmental Services, LLG 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 damaged by construction and operations. Santa Ana has extensive historical and archaeological resources which heighten the risk of impacts from new construction. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance "only affects existing structures" and therefore, there would be no change in cultural resources impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 27.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of cultural resources impacts is insufficient, finding that the STR ban would only "affect existing structures" and "construction activities would not occur." (Staff Report, Exhibit 3, p. 27.) This analysis lacks any consideration of the reasonably foreseeable construction of new hotels from an STR ban, which could result in potentially significant impacts to cultural resources, as discussed below. Construction and Operation of New Hotels The construction and operation of new hotels has the potential to result in significant environmental impacts with respect to cultural resources. Cultural resources, including historical resources, archaeological resources, and human remains, could be damaged by construction and operations. Hotels currently exist near, or may be a component of, existing designated cultural resources in urban locations in the City. As discussed above, the City has identified certain locations in its General Plan, various Specific Plans, and Zoning Code appropriate for hotels. The expansion or construction of hotels in these locations could have potential to significantly and adversely harm historically important cultural resources and undetected cultural resources covered by topsoil and require mitigation. This is particularly true given the extensive cultural and historical resources within Santa Ana. As discussed in the Addendum's discussion of the GP PEIR, "there are eight archaeological resources" recorded in the City, including four prehistoric sites, one multicomponent site, and three historic isolates, and that development involving ground disturbance in the City has potential to impact known and unknown archaeological resources. (Staff Report, Exhibit 3, p. 24.) According to the GP PEIR, "Existing Conditions Database reveals approximately 2,511 historical resources have been recorded in Santa Ana. ))24 Further, "the California Historical Resources Information System records search indicates that 23 archaeological resources were previously recorded within 0.5 mile (0.8 km) of the [General Plan] area.25 And, importantly: While the review of ethnographic and historical maps does not indicate the presence of any specific Native American archaeological resources, the proximity of mapped locations of settlements in the vicinity of the plan area indicate a high sensitivity. The presence of the Santa Ana River, a permanent water source that connects the closest mapped Native American villages, and numerous springs mapped throughout the area on the rancho plat maps indicate that there is likely a high sensitivity for Native American archaeological resources throughout the 24 City of Santa Ana, GP EIR, p. 5.4-26 (Dec. 2023), available here. 25 Id., p. 5.4-18. 17 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 plan area. This is supported by the identification of several prehistoric sites composed of habitation debris and lithic materials. Furthermore, consultation with the Gabrielino Tribe indicated that portions of the City are located within cultural and historical sensitive areas.26 As recently reported in the City of Santa Ana Transit Zoning Code (SD 84A and SD 84B) EIR (the "Transit Zoning Code EIR"): Santa Ana is most directly associated with the Gabrielino (Tongva) whose tribal territory extended north from Aliso Creek to just beyond Topanga Canyon along the Pacific Coast, and inland to the City of San Bernardino (Bean and Smith 1978). However, it should be noted that tribal boundaries were likely fluid, allowing for contact, trade and diffusion of ideas among immediately neighboring groups, such as the Juaneno and Luiseno.27 Further, as discussed in the Tribal Cultural Resources Identification Memorandum for the South Coast Technology Center Project in the City: [Santa Ana is] a region traditionally important to multiple Native American groups. In particular, these include the Gabrielino (including the Tongva and Kizh), the Juaneno or Acjachemen, and the Luiseno.28 Historical Resources State CEQA Guidelines Section 15064.5 defines a historical resource as: 1) a resource listed in or determined to be eligible by the State Historical Resources Commission for listing in the California Register of Historical Resources; 2) a resource listed in a local register of historical resources or identified as significant in a historical resource survey meeting certain state guidelines; or 3) an object, building, structure, site, area, place, record or manuscript which a lead agency determines to be significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California, provided that the lead agency's determination is supported by substantial evidence in light of the whole record. Demolition or alteration of a historic resource could result in a significant impact to that resource. Mitigation measures, if feasible, would need to be provided. However, it is likely that even with the implementation of mitigation measures, demolition or alteration of a historic resource would result in a significant impact. Indirect impacts to historical resources could occur even if a construction site itself does not contain historical resources. These impacts would be to a nearby historical resource and could be temporary (such as damage to a historical resource from construction vibration) or permanent (such as from the new development altering the setting of the adjacent historical resource such that it no longer conveys 26 Id., p. 5.4-19. 27 Transit Zoning Code EIR, p. 4.4-1. 28 Michael Baker International, Tribal Cultural Resources Identification Memorandum for the South Coast Technology Center Project, City of Santa Ana, Orange County, California, p. 6 (Apr. 2024). 18 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 significance). Mitigation measures, if feasible, could be needed to reduce indirect impacts to less than significant. Absent any feasible mitigation, impacts to historical resources could be significant. Archaeological Resources With respect to archaeological resources including human remains, there is always the possibility that such resources are uncovered during construction activities for hotel construction. The City's General Plan includes Objective 3.1 to "[m]inimize loss of natural aesthetic, historic, archeological, and paleontological resources as land is developed." The likelihood of discovering such resources depends on a number of factors, including: 1) whether a site has previously been developed; 2) the extent of excavation for any prior development; 3) the extent of excavation for the current construction (such as whether any subterranean levels would be included); 4) the types of soils at a site; and 5) whether the site is in a location of known archaeological sensitivity. Depending on the specific conditions of a site, mitigation measures may be necessary to reduce impacts with respect to archaeological resources to less than significant. Given the reasonable foreseeability of new hotel development resulting from an STR ban, the City must study whether there are cultural resources present in locations where it is reasonably foreseeable these new hotels will be built. Cultural Resources Mitigation Measures from the GP PEIR are Inapplicable The City cannot rely on the cultural resources mitigation measures from the GP PEIR to address these potentially significant impacts because, as discussed above, the Proposed Ordinance is a separate project and cannot be addressed through an Addendum to the GP PEIR and, therefore, the mitigation measures from the GP PEIR cannot be applied to this new project. Ener Overview As discussed in detail in the technical environmental analysis prepared by Ramboll, an STR ban can reasonably be expected to cause significant energy impacts for several reasons including: (1) relocating existing STR guests to less efficient hotels and other replacement facilities that recent reports indicate use more energy per guest; and (2) stimulating replacement accommodation construction and expansion that will increase energy demand related to new material manufacturing, transportation and installation, heavy equipment use, and maintenance, which use electricity and transportation fuels (primarily gas and diesel). Ramboll concluded that the STR ban would increase energy demand because hotels use more energy per person than STRs and would also increase demand for fossil fuels due to increased VMT, inconsistent with regional and state climate policy. (Ramboll Environmental Analysis, pp. 7-8.) The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the STR ban would not result in any "construction -related energy consumption" or "any physical impacts to the environment" and that there would be no new or more severe significant energy impacts beyond any identified in the GP PEIR. (Staff Report, Exhibit 3, p. 28.) This is inadequate. 19 CAJA Environmental Services, LLG 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of energy impacts is insufficient, finding that that the STR ban would not result in any "construction -related energy consumption" or "any physical impacts to the environment" and that there would be no new or more severe significant energy impacts beyond any identified in the GP PEIR. (Staff Report, Exhibit 3, p. 28.) This analysis is entirely superficial, lacking any consideration of the reasonably foreseeable impacts of an STR ban, including increased energy use from hotels within and outside of the City, and construction and operation of new hotels. Energy impacts are a significant concern for local and state policymakers and agencies. For example, the Conservation Element of the City's General Plan provides that the City should "[p]rotect air resources, improve regional and local air quality, and minimize the impacts of climate change.9929 Reducing energy use is critical to helping improve air resources and minimize the impacts of climate change. The analysis of energy use relative to applicable health, safety, and emission regulations is highly technical and relies on specialized models. The City's further analysis of energy impacts from an STR ban should be supported with a technical study prepared by a qualified expert with significant energy impact model experience. Increased Energy Use from Hotels in City and Outside City Ramboll concluded the STR ban would increase energy demands because hotels use more energy per person than STRs, using more than five times more electricity per person and more than two times more natural gas per person. (Ramboll Environmental Analysis, pp. 7-8.) This is consistent with the 2018 Cleantech analysis conclusion that significantly less energy is used when guests stay in an STR compared to a hote1.30 Further, an article published in the Small Business Institute Journal proposed that sharing economy -based accommodations are likely to consume less energy than traditional accommodations because the sharing economy takes advantage of "slack" resources which already exist, rather than creating new facilities.31 In other words, STRs use structures that already exist to provide overnight accommodations and help to alleviate demand for new hotels. 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. (Ramboll Environmental Analysis, p. 8.) By eliminating all STRs from the City, an STR ban will cause visitors to stay in existing hotels in the City, increase the electrical demand from existing hotels, increase fossil fuel consumption from vehicles, and foreseeably result in significant impacts due to wasteful, inefficient, and unnecessary consumption of energy resources. This directly conflicts with state and local renewable energy and energy efficiency plans. These impacts may be significant and cumulatively substantial and require the imposition of all feasible mitigation. If feasible mitigation is not available, impacts could be significant. The City must analyze these potential impacts. 29 General Plan, Conservation Element, CN-05. 3o Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide. 31 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, pp. 60- 61 (2017). 20 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 Construction and Operation of New Hotels The construction and operation of new hotels has the potential to result in significant environmental impacts with respect to energy. The City must also evaluate whether there is adequate infrastructure to handle the peak load from new hotels. To do so, it must request an assessment from its utility as to infrastructure needed to support these new hotels. It must also examine whether the new hotels require upgrades to utility infrastructure, requiring additional offsite construction activities, and whether the new hotels put residents and businesses at risk for localized failures due to local infrastructure limitations. In addition, the City's General Plan includes various goals and policies to promote energy conservation, including promoting "energy -efficient development patterns by clustering mixed use developments and compatible uses adjacent to public transportation." An STR ban may conflict with these goals and policies by encouraging development of hotels, which are less energy -efficient compared to STRs.32 Greenhouse Gas Emissions Overview All issues associated with the City's failure to adequately analyze air quality and energy impacts in the Addendum carry over to the City's failure to calculate GHG emissions. As discussed in the technical environmental report prepared by Ramboll, 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. (Ramboll Environmental Analysis, p. 4.) 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. (Ramboll Environmental Analysis p. 8.) The Addendum fails to address any of the potential GHG emissions impacts, concluding without supporting evidence that the STR ban would not result in a substantial increase in GHG emissions from new construction or increased occupancy levels compared to the GP EIRGP PEIR. (Staff Report, Exhibit 3, p. 33.) This is unsupported by the evidence in the record and inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of GHG emissions impacts is insufficient, finding that the STR ban would "only affect existing structures," that "GHG emissions due to construction activities would not occur," and that the STR ban is "not anticipated to result in a substantial increase in GHG emissions, either directly or indirectly." (Staff Report, Exhibit 3, p. 33.) The Addendum also concludes that the STR ban "would not result in any increase in occupancy levels analyzed in the GP PEIR and does not involve construction of any new units that might lead to an increase in GHG emissions." (Ibid.) This analysis is entirely superficial, lacking any consideration of the reasonably foreseeable impacts of an STR ban, including increased vMT, 32 General Plan, Conservation Element, CN-10. 21 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 increased GHG emissions from the construction and operation of new hotels, and construction and operation of new hotels. Increased VMT Eliminating all STRs in the City will foreseeably increase GHG emissions by displacing existing STIR guests to less regulated areas farther from their travel destinations, which will increase VMT and GHG emissions. Ramboll concluded that the STIR 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. (Ramboll Environmental Analysis, p. 4.) Increased Criteria Air Emissions from Hotels in City and Outside City Eliminating all STRs in the City will relocate existing STIR guests to less efficient hotels and other replacement facilities likely to result in greater GHG emissions than STRs. When guests stay at an STIR, significantly less energy is used, and GHG emissions are lower compared to hotel stays.33 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. (Ramboll Environmental Analysis p. 8.) This is consistent with the 2018 Cleantech analysis, which found that significantly lower GHG emissions result from a stay in an STIR compared to hotel stays,34 and the Small Business Institute Journal article, which proposed that sharing economy -based accommodations are likely to produce fewer GHG emissions than traditional accommodations because the sharing economy takes advantage of "slack" resources which already exist, rather than creating new facilities that emit additional GHGs.35 As such, GHG emission increases reasonably related to the imposition of an STIR ban will result in significant impacts to the environment and adversely affect the achievement of plans and policies adopted by state and local governments to reduce GHG emissions. Construction and Operation of New Hotels Eliminating all STRs in the City will foreseeably increase GHG emissions by stimulating replacement accommodation construction and expansion that will increase GHG emissions related to new material manufacturing, transportation and installation, heavy equipment use, and maintenance, as well as operation of these new hotels further contributing to GHG emissions increases that Ramboll projected from increased reliance on hotels. Specifically, the construction and operation of new hotels would result in the increased GHG emissions from a number of sources, including: • Construction: emissions associated with construction -related equipment and vehicle use. • Area Sources: emissions associated with the on -site use of powered equipment. 33 Airbnb, Airbnb: Helping travel grow greener, p. 3 (Mar. 2017); Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 2017 SMALL BUSINESS INST. J. 13.2, pp. 61-63. 34 Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide 35 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, p. 61 (2017). 22 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 • Energy Sources: emissions associated with electricity and natural gas use for space heating and cooling, water heating, energy consumption, and lighting. • Mobile Sources: emissions associated with associated vehicle travel. It is possible new hotels would be constructed farther from a city center or tourist destination, resulting in greater urban sprawl and VMT. • Water/Wastewater: emissions associated with energy used to pump, convey, deliver, and treat water. The GHG Mitigation Measure from the GP PEIR is Inadequate The City cannot rely on the GHG mitigation measure from the GP PEIR to address these potentially significant impacts because, as discussed above, the Proposed Ordinance is a separate project and cannot be addressed through an Addendum to the GP PEIR and, therefore, the mitigation measure from the GP PEIR cannot be applied to this new project. Moreover, the GHG mitigation measure from the GP PEIR would not provide adequate mitigation for the impacts described above, such as increased vMT from elimination of STRs, since the GHG mitigation measure merely requires tracking and monitoring GHG emissions for the Climate Action Plan, which do not help to reduce project specific GHG emissions. (See Staff Report, Exhibit 3, p. 32.) The City is Shirking its Duty to Meet State Climate Goals The City should not discount the importance of evaluating potential GHG impacts from its actions. Curtailing GHG emissions to reduce future climate impacts is one of the highest priority objectives of state and local policymakers and agencies. California has legislatively determined that GHG emissions of any kind contribute to a global climate crisis. The State Is 2022 Scoping Plan includes various recommendations that local governments can implement to align their planning and development review processes with the state's climate goals. Because an STR ban promotes new land use for development of hotels, this promotes a growth in permanent emissions sources, which are less efficient than existing STRs. The City must analyze whether an STR ban would conflict with the 2022 Scoping Plan. At the local level, the Conservation Element of the City 's General Plan provides that the City should "[p]rotect air resources, improve regional and local air quality, and minimize the impacts of climate change." 36 An STR ban may also conflict with General Plan policies to reduce GHG emissions in the City such as "coordinate[ing] air quality planning with local and regional agencies to meet or exceed State or Federal ambient air quality standards" and achieving "[c]onsistency with emission reduction goals highlighted in the Climate Action Plan ... in all major decisions on land use and investments in public infrastructure.1137 The City must analyze whether an STR ban is inconsistent with its General Plan policies. In addition, a project must demonstrate compliance with applicable GHG reduction plans. Therefore, the City's analysis should address consistency of hotel replacement facilities with relevant GHG plans and 36 Santa Ana General Plan, Conservation Element, CN-05. 37 Ibid. 23 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 policies, such as the Climate Change Scoping Plan, SCAG's Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), and any other local plans and/or policies. Reducing GHG emissions is critical to helping improve air resources and minimize the impacts of climate change. Due to the significance of this issue and the complexity of GHG emissions calculations, which require complex technical expertise and knowledge of existing and potential sources, an expert study conducted by recognized climate and emissions specialist using established emission methodologies should be prepared to support the City's GHG emissions impact analysis. The City should also prepare an analysis to quantify the GHG emissions generated from constructing these new facilities. This analysis should be prepared using CalEEMod and based on specific parameters for the proposed new uses being constructed (including size of the new use as well construction schedule, construction equipment, amount of grading, amount of hauling, etc.). Likewise, operational emissions of GHGs should be quantified using CalEEMod. The City has used a screening threshold of 3,000 MTCO2e for GHG emissions. Therefore, the results from CalEEMod should then be compared to this significance threshold to determine whether impacts would be significant. Hazards & Hazardous Materials Overview An STR ban may significantly impact related to hazards and hazardous materials from the reasonably foreseeable construction of new hotels to accommodate patrons who would have previously utilized STRs. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in hazards and hazardous materials impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 35.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of hazards and hazardous materials impacts is insufficient, finding that the STR ban would only affect existing structures, and "is not anticipated to result in physical impacts to the environment." (Staff Report, Exhibit 3, p. 35.) This analysis lacks any consideration of the reasonably foreseeable construction of new hotels from an STR ban which could result in potentially significant impacts to hazards and hazardous materials. Construction of New Hotels Development of new hotels has potential to result in impacts from hazards and hazardous materials present in the locations identified in the General Plan for new hotel accommodations. As discussed in the Addendum, the City includes 555 hazardous materials sites, with 63 active or open sites. (Staff Report, Exhibit 3, p. 34.) The City has not established a baseline condition for hazards and hazardous materials and should explain what hazardous materials are present at the locations for potential hotel development. The City should then explain how hazardous materials will be managed during construction and operation of new hotels. The City also has not explained the baseline condition of contamination at the locations for new hotel development, so the current condition of site soil, soil gas, and groundwater is not clear. The 24 CAJA Environmental Services, LLG 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 City must evaluate and disclose whether new hotel construction would release contaminants and whether that can be mitigated to understand if construction of these hotel facilities is possible. Santa Ana has extensive groundwater contamination from volatile organic compounds (VOCs) related to historic manufacturing uses in the City.38 The City has identified certain locations for new hotels but has not evaluated potential impacts from hazardous or hazardous materials in those locations, such as potential for construction to release hazardous materials into the environment. The City must evaluate this potential given that new hotel development is reasonably foreseeable. Land Use / Planning Overview The STR ban is reasonably likely to have significant land use and planning impacts by eliminating all STRs in the City, and from the reasonably foreseeable construction of new hotels to accommodate patrons who would have previously utilized STRs. The STR ban also has potential to result in significant land use impacts due to urban decay. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in land use and planning impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 37.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of land use and planning impacts is insufficient, finding that the STR ban would only affect existing structures, and "is not anticipated to result in physical impacts to the environment." (Staff Report, Exhibit 3, p. 37.) The Addendum notes that the STR ban would "improve the connectivity of existing communities by improving the compatibility of existing uses and preserving the character and integrity of existing neighborhoods (Land Use Element Goal 3) through the prohibition of STRs within long- term residential neighborhoods." (Id., p. 38.) The analysis in the Addendum lacks any consideration of the reasonably foreseeable land use impacts resulting from eliminating all STRs, construction of new hotels, and urban decay from the STR ban. Inconsistency with General Plan The City failed to adequately analyze the consistency of the STR ban with its General Plan, narrowly focusing only on the goal of preserving the character or residential neighborhoods. (Staff Report, Exhibit 3, pp. 37-38 [citing to Land Use Element Goal 31.) The STR ban's elimination of all existing STRs in the City is inconsistent with the City's General Plan Land Use Element when viewed holistically and in the context of the entire General , which contemplates efficient use of City land and maximizing efficient use of City resources, including a variety of goals and policies for responsible development in the City.39 For example, Land Use Element Goal LU-2 is aimed at providing a balance of land uses to meet the City's 38 City of Santa Ana, Delhi Groundwater, available here: https://www.santa-ana.org/delhi- groundwater/#:—:text=This%20groundwater%20is%20contaminated%20near,of%20Santa%20Ana%27s%20drinkin g%20water (last visited Oct. 7, 2024). 39 See Santa Ana General Plan, Land Use Element. 25 CAJA Environmental Services, LLG 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 diverse needs.40 Policy LU-4.3 "encourage[s] land uses and strategies that reduce energy and water consumption, waste and noise generation, soil contamination, air quality impact, and light pollution.9941 As discussed above, a 2018 Cleantech analysis found that when guests stay at an STIR, significantly less energy and water is used, greenhouse gas emissions are lower, and waste is reduced, compared to hotel stays42 and an article published in the Small Business Institute Journal also proposed that sharing economy based accommodations are likely to consume less energy and water, and produce fewer GHG emissions and less waste, than traditional accommodations.43 By removing the ability of hosts to operate STRs from existing residences, the City is acting in a manner inconsistent with its Land Use Element policy to encourage resources efficient land uses. The City is inappropriately relying entirely on the Land Use Element goal of preserving the character of residential neighborhoods, without any substantial evidence to demonstrate that STRs in the City are having a negative impact on the character of residential neighborhoods and ignoring the other goals and policies of the Land Use Element. Construction of New Hotels It is reasonably foreseeable that an STIR ban will disperse existing STIR users to other locations that permit STRs and induce hotel development. These changes from existing conditions could foreseeably conflict with the City's General Plan plans, policies, and regulations, requiring analysis under CEQA as to whether there would be a significant environmental impact due to a conflict with a land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. The City's General Plan Land Use Element, Policy LU-4.5 aims to "[c]oncentrate development along high quality transit corridors to reduce vehicle miles traveled (VMT) and transportation -related carbon emissions.9944 As discussed above, the City has identified in its General Plan, Specific Plans, and Zoning Code certain locations for hotel development. Many of these locations identified for potential development of new hotels may not be centrally located to promote sustainable development, an STIR ban may be inconsistent with the City's General Plan. Urban Decay An STIR ban also has potential to result in urban decay, which the City must analyze. Loss of business revenue from tourists unable to secure alternative lodging and unwilling to travel from neighboring areas to the City could cause distressing effects in the business community, potentially leading to business closures and urban decay. The STIR market contributes to the local economy by employing many people, including those working pool service, drycleaning, upholstery, catering, bike rentals, yoga studios, transportation, restaurants, wineries, tasting rooms, groceries, home repair and improvement, nurseries and landscaping, and 40 General Plan, Land Use Element, LU-5. 41 Ibid. 42 Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmental) -friendly-travel-worldwide. 43 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, pp. 61- 63 (2017). 44 Santa Ana General Plan, Land Use Element, LU-08. W CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 household supplies. As discussed above, STRs compete with hotels by offering a different sort of service with a unique structure, and STRs "pop up throughout cities where there is demand for lodging. They do not require centralization... Rentals offer a more sustainable option that requires fewer resources and helps increase access with more diverse accommodation options and better value.9145 Further, STRs "are critical to regional economies, offering unique and affordable experiences to visitors, generating significant tax revenue to support local governments, and providing hosts significant income.9946 An STR ban could have devastating effects on local businesses, including restaurants and small businesses, that are not in the areas where hotels exist or would be developed. As set forth in the Economic Prosperity Element of the City's General Plan, the City has established goals of attracting businesses to "strengthen and expand citywide business attraction efforts in order to achieve the city's full employment potential," and "stimulate the local economy through tourism."47 The City did not analyze any of the potential impacts of an STR ban to this sector of the economy and how this could contribute to urban decay and conflict with the City's General Plan. Potential for lost revenue from tourism is discussed in greater detail in the economic analysis prepared by Ramboll. The City must evaluate this evidence in an EIR. Noise and Vibration Overview Ramboll concluded that there are a number of potentially significant noise impacts that could result from an STR ban and require further analysis by the City. Increased use of existing hotels due to loss of all STRs in the City is reasonably likely to lead to increased operational and traffic noise impacts, which may be significant. Further, it is reasonably foreseeable that additional hotels or other similar facilities would need to be constructed to accommodate patrons who would have previously utilized STRs, and this construction has the potential to result in significant noise and vibration impacts. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in noise impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 41.) The Addendum does not even discuss potential vibration impacts in its evaluation of the STR ban. (See Id., p. 41.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of noise impacts is insufficient, finding that the STR ban would only affect existing structures, "[n]o impacts related to construction -related noise level increases would occur," and no increases in transportation noise are anticipated. (Staff Report, Exhibit 3, p. 41.) The Addendum does not even address potential vibration impacts from construction of new hotels. The analysis in the Addendum lacks any consideration of the reasonably foreseeable noise impacts resulting from construction and operation of new hotels. 45 King and Jenkins, Unequal Access: Protecting Affordable Accommodations Along the California Coast (2020). 46 Dubetz et al, Staying Power.- The Effects on Short -Term Rentals on California's Tourism Economy and Housing Affordability, Milken Institute, p. 1 (2022). 47 Santa Ana General Plan, Economic Prosperity Element, EP 04. 27 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 Operation of Existing Hotels The elimination of all STRs in the City is reasonably likely to cause increased demand for existing hotel accommodations in the City. Ramboll concluded the STIR ban could concentrate traffic on roadways going to hotels in the area, since more than half of the 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 noise impact. (Ramboll Environmental Analysis, pp. 9-10.) The City failed to evaluate how the potential noise and nuisance complaints associated with hotels may be greater than those associated with STRs. To understand the potential impacts from increased use of existing hotels, the City should calculate the total noise complaints associated with STRs it has received, and the total noise complaints associated with hotels, to understand if there is any appreciable difference between the noise complaints received from these accommodations. The City also failed to analyze how this increased demand could lead to potentially significant operational noise impacts from visitors using the facilities, including outdoors areas of hotels such as pools and recreation areas. The City must analyze these potential impacts from the increased use of existing hotels. In addition, it is likely that restricting the use of STRs would require patrons to stay at a hotel or other facility that is further from their intended destination, again resulting in increased vMT, and potentially higher noise levels from increased traffic. As discussed in the technical environmental analysis prepared by Ramboll, shifting traffic to residential or other noise -sensitive areas within the City that are currently below the City's noise threshold could result in a significant impact. The City must evaluate this potential impact. Construction of New Hotels Ramboll estimates the STIR ban will potentially cause significant noise impacts related to hotel construction, exceeding the City's General Plan Noise Element standard and the City's noise ordinance. (Ramboll Environmental Analysis, pp. 11-12.) Construction equipment including heavy machinery can result in significant noise impacts, with sound levels ranging from approximately 75 to 90 dBA (typical suburban/urban background sound levels are commonly on the order of 45 to 55 dBA during daytime hours and lower during nighttime hours) assuming typical receptor distances of 500 ft to 50 ft, and construction may sometimes need to occur at night due to various limitations or time constraints, which may be particularly prevalent over the next few years as hotel construction in Southern California increases to meet hotel demand for the 2028 Olympics. (Ramboll Environmental Analysis, p. 13.) Because sound pressure levels from construction of new hotels, which will be needed due to the STIR ban, have the potential to cause a temporary increase above the noise level threshold, the City must conduct further analysis to evaluate potentially significant impacts and any necessary mitigation. (Ramboll Environmental Analysis, pp. 13-14.) The City should prepare an analysis to quantify projected noise levels from construction of the new hotels in the designated areas identified in the General Plan, Specific Plans, and Zoning Code for hotel development. This analysis should be based on specific parameters for the proposed new uses being 28 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 constructed (including size and placement of the new use as well construction schedule, construction equipment, amount of grading, amount of hauling, etc.). The increase in noise from construction should then be compared against the threshold to determine whether the increase in noise is greater than the threshold, in which case there would be a potentially significant impact. The likelihood of significant impacts increases where there are sensitive uses (such as residences) in close proximity to construction. If potentially significant impacts have been identified, mitigation measures, if feasible, would need to be provided to reduce impacts to less than significant. If feasible mitigation is not available (which for noise, it often is not feasible), impacts could be significant. Regarding construction vibration impacts, depending on the proximity of adjacent sensitive receptors, an analysis should be prepared to quantify projected vibration levels from construction of new replacement facilities. For example, if a new hotel is constructed in an area adjacent to a historical or archaeological resource, the City must evaluate whether there could be building damage caused to those resources. The increase in vibration from construction should be compared against the applicable thresholds for both building damage and human annoyance to determine whether the increase in vibration is greater than the threshold, in which case there would be a potentially significant impact. The likelihood of significant impacts increases where there are sensitive uses (such as residences) in close proximity to construction. If potentially significant impacts have been identified, mitigation measures, if feasible, would need to be provided to reduce impacts to less than significant. It is likely that there would be feasible mitigation for building damage impacts (such as monitoring a building during vibration -producing activities). Conversely, it is difficult to mitigate human annoyance impacts beyond increasing the distance from the construction activity to the sensitive receptor. Therefore, if you have a sensitive receptor adjacent to vibration -producing construction activity, you could have a significant impact with respect to human annoyance. Operation of New Hotels All issues associated with the potential operational noise impacts from existing hotels apply to the City's failure to calculate potential noise impacts from operation of new hotels. Adding more hotels to the City's existing hotel stock would further concentrate traffic on roadways going to hotels in the area 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 noise impact. (Ramboll Environmental Analysis, p. 9.) Further, it is possible that to avoid the potentially significant impacts associated with adding more hotels to the areas of the City that already have several hotels, new hotels would be constructed farther from a city center or tourist destination, resulting in greater urban sprawl and vMT, which could result in higher noise levels from increased traffic in these areas. These new hotels would also produce noise from mechanical equipment, parking facilities, loading docks, and amenity spaces. The City must evaluate the potential for noise complaints associated with operation of new hotels to determine whether there would be a significant impact. 29 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 Public Services Overview There are a number of potentially significant impacts with respect to public services that could result from an STR ban and require further analysis by the City. Increased utilization of existing hotels as a result of eliminating all STRs in the City is reasonably likely to lead to increased demand for public services, which may be significant. Further, as mentioned above, it is reasonably foreseeable that additional hotels would need to be constructed to accommodate patrons who would have previously utilized STRs. The operation of new hotels has the potential to result in significant environmental impacts with respect to public services. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in public services impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 44.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of impacts to public services from the STR ban is insufficient, finding that the STR ban would only affect existing structures, and that the STR ban would not "introduce new residential units to the city" and that the "residential units illegally operating as STRs were adequately analyzed in the GP PEIR" as part of the GP buildout. (Staff Report, Exhibit 3, p. 44.) The analysis in the Addendum lacks any consideration of the reasonably foreseeable impacts to public services resulting from operation of existing and new hotels. Operation of Existing Hotels As discussed above in the Noise and vibration section, the City failed to evaluate how the potential for noise and nuisance complaints associated with hotels may be greater than those associated with STRs. The City must evaluate the potential for increased demand for public services due to those complaints, which may be significant. Operation of New Hotels With respect to impacts to fire and police facilities, STR restrictions that could result in the construction of new replacement hotels or other facilities would result in increased demand for fire and police protection facilities to maintain acceptable service ratios, response times, or other performance objectives. The City should provide a calculation of the number of calls to police complaining about hotels compared to the number of calls to police regarding STRs, to analyze whether eliminating all STRs and increasing hotel use would increase demand for police services. Mitigation measures may need to be provided to reduce impacts to less than significant. Absent any feasible mitigation, impacts to public services (specifically fire and police) could be significant. 30 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 Transportation Overview As discussed in the air quality, energy, and GHG emissions sections above, it is reasonably foreseeable that an STR ban will increase total and peak period transportation demand, trip counts, and VMT in several ways, including (1) by displacing existing STR guests to STRs and hotels located farther away from travel destinations; and (2) stimulating STR replacement accommodation construction and expansion that will increase construction period and operational period material, service supplier, maintenance and traveler vehicle trips and VMT. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures," would not conflict with regional or local circulation system planning, and that the operational traffic associated with long-term rentals or permanent residences (which the Addendum assumes all STRs would be converted to) was already evaluated in the GP PEIR. Therefore, the Addendum concludes there would be no change to transportation impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 46.) This is inadequate. The impacts described above would significantly conflict with plans, ordinances and polices addressing circulation systems, including transportation system congestion reduction, energy conservation, and criteria and GHG emission reduction goals. Additional VMT generation will significantly conflict with CEQA guidelines Section 15064.3(b), which requires that a CEQA analysis consider and reduce VMT. These impacts would require the imposition of all feasible mitigation under CEQA. The City failed to conduct any analysis of these potential impacts. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of transportation impacts from the STR ban is insufficient, finding that the STR ban would only affect existing structures, and that the STR ban would not conflict with regional or local circulation system planning, and that the operational traffic associated with long-term rentals or permanent residences (which the Addendum assumes all STRs would be converted to) was already evaluated in the GP PEIR. (Staff Report, Exhibit 3, p. 46.) The analysis in the Addendum lacks any consideration of the reasonably foreseeable transportation impacts from increased VMT related to existing and new hotels which will result from eliminating all STRs in the City. Increased VMT— Existing Hotels It is likely that restricting the use of STRs would require patrons to stay at a location (hotel or other facility) that is further from their intended destination, resulting in increased VMT. Guests staying in STRs have more flexibility to stay closer to their destinations, by eliminating STRs in the City, these travelers will need to travel further to reach their destinations. This increase in VMT will additionally lead to an increase in other potentially significant environmental impacts, including GHG emissions and air quality, as discussed above. The ITE Trip Generation Manual, 11 th edition, does not provide average trip rates specifically for STRs. The land use category in the ITE Trip Generation Manual that most closely matches at STR is Land Use 31 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 260: Recreational Home, which is defined as either (1) a second home used by its owner periodically for recreation or (2) a home rented on a seasonal basis. No additional trip generation data or studies were available from other sources that would be more applicable to an STR ban. Thus, the recreational homeland use (Land Use 260) from the ITE Trip Generation Manual is the most appropriate representative land use for the purposes of analyzing trip generation for STRs. Recreational homes generate less trips than hotels.48 Given the evidence that hotels generate more traffic than STRs, which due to STR ban may result in a significant increase in VMT, the City should evaluate these potential impacts in an EIR. Further, because California state and local policymakers and agencies are sensitive to transportation system and VMT impacts, an expert study should be conducted by a recognized transportation specialist using established travel demand and VMT methodologies to include in the EIR. This analysis should estimate the individual vehicle trips and average trip lengths associated with STRs in Santa Ana, compared with those associated with hotel stays in Santa Ana, to evaluate the increase in VMT from eliminating STRs in the City. This would use the ITE model to quantify the VMT associated with the current baseline conditions where STRs are permitted, with regional travel demand based on residential use and proximity to tourist areas. This should be compared against a scenario where STR uses have been eliminated and there is an increased demand for hotels further from tourist areas. If the increase in VMT from an STR ban exceeds the applicable threshold, transportation impacts could be significant and mitigation measures would need to be provided to reduce impacts to less than significant. Absent any feasible mitigation, impacts to transportation (VMT) could be significant. Increased VMT— New Hotels Based on the locations identified in the City's General Plan, Specific Plan, and Zoning Code as locations for development of new hotels, depending on the availability of land suitable for hotel development in these areas, there is a reasonable possibility these new hotels would be constructed farther from a city center or tourist destination, resulting in greater urban sprawl and VMT, which could result increased traffic. Thus, for the reasons discussed above regarding existing hotels, the City must analyze potential VMT impacts associated with potential new hotels. Tribal Cultural Resources Overview An STR ban may significantly impact tribal cultural resources from the reasonably foreseeable construction and operation of new hotels to accommodate patrons who would have previously utilized STRs. Santa Ana has extensive tribal cultural resources which heighten the risk of impacts from new construction. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in 48 ITE 2021. 32 CAJA Environmental Services, LLO 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 impacts to tribal cultural resources beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 47.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of tribal cultural resources impacts is insufficient, finding that the STR ban would only affect existing structures and there would be "no earthwork or ground -disturbing activities." (Staff Report, Exhibit 3, p. 47.) This analysis lacks any consideration of the reasonably foreseeable construction of new hotels from an STR ban which could result in potentially significant impacts to tribal cultural resources, as discussed below. Construction and Operation of New Hotels The presence of tribal cultural resources in Santa Ana are discussed above in the Cultural Resources section. The same issues applicable to the potential for disturbance of cultural resources as a result of construction of new hotels apply to tribal cultural resources. As discussed above in the Cultural Resources section, tribal cultural resources that could be present in Santa Ana include Native American burial sites, village or occupation sites, and traditional resource - gathering locations. For example, the Gabrielino (or Tongva and Kizh), Juaneno (or Acjachemen), Luiseno peoples inhabited the region and there may be tribal cultural resources present in the sites for new hotel development that must be surveyed.49 In addition, AB 52 establishes a formal consultation process for California Native American Tribes to identify potential significant impacts to tribal cultural resources. Depending on the specific conditions of a site, as well as the results of tribal consultation conducted pursuant to AB 52, mitigation measures may be necessary to reduce impacts with respect to tribal cultural resources to less than significant. The City must conduct tribal consultation in compliance with SB 18 and AB 52. Utilities / Service Systems Overview The prohibition of STRs is reasonably likely to significantly impact utilities and services systems by increasing demand for water, electricity, natural gas, and increased generation of wastewater and solid waste. As discussed above, a 2018 Cleantech analysis found that when guests stay at an STR, significantly less energy and water is used, greenhouse gas emissions are lower, and waste is reduced, compared to hotel stays50 and an article published in the Small Business Institute Journal also proposed that sharing economy based accommodations are likely to consume less energy and water, and produce fewer GHG emissions and less waste, than traditional accommodations .51 By increasing demand for these services 49 Michael Baker International, Tribal Cultural Resources Identification Memorandum for the South Coast Technology Center Project, City of Santa Ana, Orange County, California, p. 6 (Apr. 2024). 51 Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide. 51 Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 2, pp. 61- 63 (2017). 33 CAJA Environmental Services, LLG 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 both from existing hotels, and from potential new hotels, an STR ban could result in significant impacts to utilities and services systems. The Addendum fails to address any of these potential impacts, concluding without supporting evidence that the Proposed Ordinance would "only affect existing structures" and therefore, there would be no change in utilities and service systems impacts beyond those identified in the GP PEIR. (Staff Report, Exhibit 3, p. 48.) This is inadequate. The Analysis in the Addendum Fails to Address Potentially Significant Impacts The Addendum's analysis of impacts to utilities and service systems from the STR ban is insufficient, finding that the STR ban would only affect existing structures, and that the ban "would not require development of any kind" so there would be no increase in demands to utilities and service systems. (Staff Report, Exhibit 3, p. 48.) The analysis in the Addendum lacks any consideration of the reasonably foreseeable impacts to utilities and service systems resulting from operation of existing and new hotels. Operation of Existing Hotels - Water By increasing visitor demand for existing hotels, an STR ban has potential to result in increased demand for water, electricity, and natural gas, and the increased generation of wastewater and solid waste, which could result in the need for the construction or expansion of water or wastewater treatment facilities, landfills, storm water drainage facilities, electric power facilities, natural gas facilities, or telecommunications facilities. STR guests use the typical amount of water used in a residential home, which is substantially less water than hotel guests.52 According to the 2018 Cleantech analysis, by staying in Airbnb listings rather than hotels in 2017, Airbnb guests in Europe reduced water usage equal to 13,000 Olympic -sized swimming pools. Because an STR ban will eliminate all STRs in the City, it is reasonably foreseeable that the number of guests staying in higher water use facilities like hotels will increase resulting in a greater demand for water. Water efficiency is a key issue for state policymakers that the City should not discount. California's potable and higher quality, potentially potable irrigation water supplies have been substantially reduced by state and local surface groundwater regulatory constraints and during multiple year droughts notwithstanding the most recent two years of higher -than -normal precipitation. Almost all urban areas of the state do not have sufficient water supplies to meet current and projected future demands over time, and eliminating lower -demand STR uses from the City 's overnight accommodations market will place an even greater strain on the City 's water supply. In addition, the Conservation Element of the City's General Plan provides that the City should "collaborate with Orange County Water District and Metropolitan Water District to ensure reliable, adequate, and high -quality sources of water supply at a reasonable cost."53 Due to the 52 Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide; Midgett et al., The Sharing Economy and Sustainability: A Case for Airbnb, 13 SMALL BUSINESS INST. J. 21 pp. 61-63 (2017). 53 Santa Ana General Plan, Conservation Element, CN 12. 34 CAJA Environmental Services, LLC 9410 Topanga Canyon Blvd., Suite 101 Chatsworth, CA 91311 Phone 310-469-6700 Fax 310-806-9801 significance of these concerns, the City should prepare a Water Supply Assessment prior to moving forward with an STR ban.54 Operation of Existing Hotels — Solid Waste Regarding solid waste, local, regional, state, and federal statutes and regulations require that the volume of solid waste generation and disposal be reduced overtime, including through use of solid waste reduction programs such as recycling and composting. According to the 2018 Cleantech analysis, Airbnb guests in North America achieved a waste reduction of 64,000 tons.55 An STR ban would increase hotel accommodation solid waste volumes and significantly and cumulatively impact the achievement of solid waste reduction goals and compliance with local and state solid waste statutes and regulations. The City must conduct a study of solid waste generation rates in STRs compared to hotels and calculate the reasonably foreseeable solid waste volume increases that would result from a ban on STRs. Given the sensitivity of California state and local policymakers to solid waste reduction programs, an expert study should be prepared by a qualified waste management expert to support this analysis. Operation of New Hotels All potential impacts to utilities and services systems discussed above regarding operation of existing hotels apply to the operation of potential new hotels. In addition, operation of new hotels will also result in a demand for landscaping, cleaning, and maintenance services. These impacts may be significant in areas of the City where STRs are more prevalent and hotel options are limited or nonexistent. Construction of new hotels would also increase demand for utility services generally. The City's analysis of impacts to utilities in an EIR should also calculate the demand for utilities from the new hotel facilities and determine whether the applicable facilities can accommodate the increase in demand. If existing facilities cannot accommodate the increased utility demand resulting from an STR ban and subsequent addition of new hotel facilities, new or expanded facilities could be required to accommodate this demand (e.g., for water and electricity), the construction of which could be a significant environmental impact. Mitigation measures may need to be provided to reduce impacts to less than significant. Absent any feasible mitigation, impacts to utilities and service systems could be significant. 54 The California Water Code (§10910 et. seq.), based on Senate Bill 610 of 2001 (SB 610), requires a project proponent to assess the reliability of a project's water supply as part of the CEQA process. 55 Airbnb, How the Airbnb Community Supports Environmentally -Friendly Travel Worldwide (Apr. 2018), https://news.airbnb.com/how-the-airbnb-community-supports-environmentally-friendly-travel-worldwide. 35 Ramboll Environmental Analysis ENVIRONMENT & HEALTH MEMO To File From Eric C. Lu, Sarah Manzano, and Brent Ferren Subject ENVIRONMENTAL ANALYSIS OF SHORT-TERM RENTAL REGULATION Ramboll Americas Engineering Solutions, Inc. (Ramboll) evaluated potential air Date: November 14, 2024 quality, greenhouse gas (GHG), energy and noise environmental impacts of a potential ban on short-term rentals (STR) in Santa Ana, California. As discussed throughout this memo, Ramboll found that the ban of STRs in Santa Ana has the potential to increase emissions and noise that should be evaluated further. The increase in emissions and noise have the potential to cause a significant impact in relation to California Environmental Quality Act (CEQA). Ramboll's analysis was informed by the economic analysis performed by Ramboll's Stefanie O'Gorman Ramboll (see Exhibit A) . 250 Montgomery St., Suite 1200 San Francisco, CA 94104 US 1 Overview USA T+ 1 510 655 7400 As a result of the proposed STR ban, individuals would be unable to enjoy the F+1 510 655 9517 benefits of STRs within Santa Ana, which will increase demand for local hotels as https://ramboll.com the only option for short term stays within Santa Ana. As a result, individuals will be forced to travel greater distances to other commercials centers in the region to find available STRs and available/affordable hotels, introducing additional vehicle miles traveled (VMT). In particular, increased travel to and from hotels and STRs in the region because of the unavailability of STR in Santa Ana could increase emissions relative to South Coast Air Quality Management District (SCAQMD) thresholds for criteria air pollutants (CAPs), with the potential to cause short-term and long-term health impacts to sensitive receptors, exceedances of appliable air quality standards, and inconsistencies with applicable air quality and climate plans, all of which create a fair argument of environmental impacts that need to be studied further under CEQA. The ban of STRs will also likely result in increased traffic congestion and noise impacts that require further study under CEQA.1, 2 1 Airbtics reports approximately 1,000 short-term rentals in Santa Ana, which is referenced throughout this analysis. However, conclusions herein are largely based on comparative impacts to the elimination of short-term rentals and are not dependent on the actual number of short term rentals in Santa Ana today. 2 https://app.airbtics.com/airbnb-data/united-states/CA/santa%20ana 1/14 2 Health Impacts from Criteria Pollutants Criteria air pollutants (CAPs) are defined as pollutants for which the federal and state governments have established ambient air quality standards, or criteria, for outdoor concentrations to protect public health. The federal and state standards have been set, with an adequate margin of safety, at levels above which concentrations could be harmful to human health and welfare. These standards are designed to protect the most sensitive people from illness or discomfort. Pollutants of concern include ozone (03), nitrogen oxides (NOx), carbon monoxide (CO), sulfur oxides (SOX), particulate matter less than 10 microns in diameter (PM1o), and particulate matter less than 2.5 microns in diameter (PM2.5). The STR ban has the potential to increase emissions of these pollutants and their health impacts are discussed in the following paragraphs. Ozone 03 is a colorless gas that is formed in the atmosphere when volatile organic compounds (VOCs), sometimes referred to as reactive organic gases (ROG), and oxides of nitrogen (NOx) react in the presence of ultraviolet sunlight. 03 is not a primary pollutant; it is a secondary pollutant formed by complex interactions of two pollutants directly emitted into the atmosphere. The primary sources of VOCs and NOx, the precursors of 03, are automobile exhaust and industrial sources. Meteorology and terrain play major roles in 03 formation, and ideal conditions occur during summer and early autumn on days with low wind speeds or stagnant air, warm temperatures, and cloudless skies. Short-term exposures (lasting for a few hours) to 03 at levels typically observed in Southern California can result in breathing pattern changes, reduction of breathing capacity, increased susceptibility to infections, inflammation of the lung tissue, and some immunological changes. Nitrogen Oxides Most NO2, like 03, is not directly emitted into the atmosphere but is formed by an atmospheric chemical reaction between nitric oxide (NO) and atmospheric oxygen. NO and NO2 are collectively referred to as NOx and are major contributors to 03 formation. The primary sources of NO, the precursor to NO2, include automobile exhaust and industrial sources. High concentrations of NO2 can cause breathing difficulties and result in a brownish -red cast to the atmosphere, causing reduced visibility. There is some indication of a relationship between NO2 and chronic pulmonary fibrosis, and some increase in bronchitis in children (2 and 3 years old) has also been observed at concentrations below 0.3 parts per million by volume (ppm). Carbon Monoxide Carbon Monoxide (CO) is a colorless and odorless gas formed by the incomplete combustion of fossil fuels. CO is emitted almost exclusively from motor vehicles, power plants, refineries, industrial boilers, ships, aircraft, and trains. In urban areas, such as Santa Ana, automobile exhaust accounts for the majority of CO emissions. CO is a non -reactive air pollutant that dissipates relatively quickly; therefore, ambient CO concentrations generally follow the spatial and temporal distributions of vehicular traffic. CO concentrations are influenced by local meteorological conditions, primarily wind speed, topography, and atmospheric stability. CO from motor vehicle exhaust can become locally concentrated when surface - based temperature inversions are combined with calm atmospheric conditions, a typical situation at dusk in urban areas between November and February. The highest levels of CO typically occur during the colder months of the year when inversion conditions, where a layer of warm air sits atop cool air, 2/14 R&M B dLL are more frequent and can trap pollutants close to the ground. In terms of health, CO competes with oxygen, often replacing it in the blood, thus reducing the blood's ability to transport oxygen to vital organs. The results of excess CO exposure can be dizziness, fatigue, and impairment of central nervous system functions. Sulfur Oxides Sulfur Dioxide (S02) is a colorless, pungent gas formed primarily by the combustion of sulfur -containing fossil fuels. The main sources of S02 are coal and oil used in power plants and industries; as such, the highest levels of S02 are generally found near large industrial complexes. In recent years, S02 concentrations have been reduced by the increasingly stringent controls placed on stationary source emissions of S02 and limits placed on the sulfur content of fuels. S02 is an irritant gas that attacks the throat and lungs and can cause acute respiratory symptoms and diminished ventilator function in children. S02 can also yellow plant leaves and erode iron and steel. Particulate Matter Particulate matter (PM) pollution consists of very small liquid and solid particles floating in the air, which can include smoke, soot, dust, salts, acids, and metals. Particulate matter can form when gases emitted from industries and motor vehicles undergo chemical reactions in the atmosphere. PM2.5 and PM10 represent fractions of particulate matter. Fine particulate matter, or PM2.5, is roughly 1/28 the diameter of a human hair. PM2.5 results from fuel combustion (e.g., motor vehicles, power generation, and industrial facilities), residential fireplaces, and woodstoves. In addition, PM2.5 can be formed in the atmosphere from gases such as sulfur oxides (SOx), NOx, and VOCs. Inhalable or coarse particulate matter, or PM1o, is about one- seventh the thickness of a human hair. Major sources of PM10 include dust stirred up by vehicles traveling on roads; crushing or grinding operations; wood -burning stoves and fireplaces; dust from construction, landfills, and agriculture; wildfires and brush/waste burning; industrial sources; windblown dust from open lands; and atmospheric chemical and photochemical reactions. PM2.5 and PM10 pose a greater health risk than larger -size particles. When inhaled, these tiny particles can penetrate the human respiratory system's natural defenses and damage the respiratory tract. PM2.5 and PM10 can increase the number and severity of asthma attacks, cause or aggravate bronchitis and other lung diseases, and reduce the body's ability to fight infections. Very small particles of substances such as lead, sulfates, and nitrates can cause lung damage directly or be absorbed into the bloodstream, causing damage elsewhere in the body. Additionally, these substances can transport absorbed gases, such as chlorides or ammonium, into the lungs, also causing injury. Whereas PM10 tends to collect in the upper portion of the respiratory system, PM2.5 is so tiny that it can penetrate deeper into the lungs and damage lung tissues. Suspended particulates also damage and discolor surfaces on which they settle, as well as produce haze and reduce regional visibility. 3 An STR Ban Will Increase Air Pollutant Emissions and Greenhouse Gas Emissions There are approximately 1,000 active Airbnb listings in Santa Ana. Elimination of these Airbnb rentals and other short-term rentals in Santa Ana and the corresponding increase in guests at Santa Ana hotels 3/14 M B dLL would result in an increased trip length, as potential guests would have fewer options to stay as close as possible to daily destinations during their stay in Santa Ana. In addition, the number of trips taken by guests to and from their site of accommodation would be higher for hotels than for short-term rentals, as evidenced by Institute of Transportation Engineers (ITE), introducing additional vehicle miles traveled. Recreational Homes (ITE Land Use Code 260) have an average weekday trip generation rate of 3.55 trips per day while the Hotel land use (ITE Land Use 310) has 7.99 trips per day. This increase in trips may be due to the need to leave the hotel for amenities, such as food, and increased worker trips. The increase in mobile emissions associated with short-term rentals compared to hotels is presented below in Table 1. Based on publicly available statistics on the current Airbnb listings in Santa Ana, the average capacity per STR is 5.6 people and there are approximately 1,000 active Airbnb listings.3 This results in a service population of 5,600 people. As a result of the potential STR ban, this would require 1,867 hotel rooms to accommodate this same service population assuming one hotel room has a capacity of 3 people. The number of peak daily trips was estimated using the ITE trip rates for STRs and hotel rooms and the number of STRs and hotel rooms required to serve the same population. The number of daily miles traveled was estimated assuming a single trip to a hotel is 2 miles longer than a single trip to a STR since guests might have to stay farther from daily destinations if they stay at a hotel. These assumptions were used to determine daily mobile emissions. Mobile emissions from visitors staying at a hotel would generate up to 444 percent more criteria air pollutant emissions and GHGs than from visitors staying at an STR.4 Therefore, the ban has the potential to considerably increase emissions in the area. The increase in VMT and greenhouse gas emissions is directly inconsistent with regional and state goals to reduce VMT and greenhouse gas emissions from vehicle trips. Additional calculation details can be found in Appendix A. Table 1. Emissions Increase due to Additional VMT Criteria Air Pollutant Percent Increase in daily mobile emissions from STR to hotel to serve the same population VOC 442% NOx 443% CO 443% sox 444% PM io 444% PM2.5 444% GHG (CO2e) 443% https://app.airbtics.com/airbnb-data/united-states/CA/santa%20ana This percent increase is independent of the number of short-term rentals in Santa Ana. The number of short-term rentals and population are provided for illustrative purposes only. 4/14 4 An STR Ban Will Disproportionally Burden Environmental Justice Communities The proposed STR ban in Santa Ana, CA, raises critical environmental justice concerns, particularly given the City's existing pollution burdens from regional pollution and localized traffic exposure near the existing hotel stock, and the potential for increased hotel usage in response to restrictions on STRs. The existing hotels are predominately located near the I-5 and 55 freeways on the southeastern boundary of the City. This area shows elevated burden according to the California Office of Environmental Health Hazard Assessment (OEHHA) CalEnviroScreen (CalEnviroScreen 4.0) data.5 CalEnviroScreen was developed as a mapping tool that identifies California communities most impacted by pollution and other environmental risks to identify vulnerability to adverse health effects from those sources. CalEnviroScreen takes into account environmental and socioeconomic factors to develop a percentile of burden across the State of California. Factors include indicators of pollution burden (including ozone, traffic, pesticides, drinking water) and population characteristics (including asthma, cardiovascular disease, education, poverty), which are each scored and weighted to derive a pollution burden score, population characteristic score, and the final CalEnviroScreen score. The Santa Ana tracts that border the I-5 and 55 freeways near the Southeastern boundaries of the city are identified as vulnerable tracts are also the current locations for the greatest density of hotels in Santa Ana. As shown in Figure 1, the CalEnviroScreen tool identifies Santa Ana, and particularly the freeway - adjacent tracts, as highly burdened, being classified into the 80t" percentile and above for the CalEnviroScreen overall percentile, with tracts above the 90t" percentile (Tract 6059074406 93rd percentile as the maximum). This significant elevation in burden is driven by the pollution and exposure burden; these freeway -adjacent tracts are ranked in the 90t" percentile and above for pollution burden (Tract 6059074003 99t" percentile for pollution burden) and face extreme burden from air pollution associated with vehicle traffic emissions, and direct traffic exposure (Tract 6059074406 99t" percentile for traffic). Conversely, while central Santa Ana tracts still register as overburdened and pollution -impacted, tracts in the center of the City are comparatively lower burdened and near the 70t" percentile for overall burden. Further screening tools, the Council on Environmental Quality's Climate and Economic Justice Screening Tool (CEJST),6 the US EPA's Environmental Justice Screening and Mapping Tool (EJScreen, Version 2.3),7 and the Public Health Alliance of Southern California's California Health Places Index (HPI 3.0),$ each highlight significant environmental and health concerns for Santa Ana in almost all tracts, with traffic proximity and the associated vehicle traffic -generated air pollution as the driving metrics of those disadvantage and burden ratings. 5 OEHHA. CalEnviroScreen 4.0. May 2023. Available at: https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. 6 Council on Environmental Quality. Climate and Economic Justice Screening Tool. Available at: https://screeningtool.geoplatform.gov/en/. 7 US EPA. Environmental Justice Screening and Mapping Tool. Available at: https://www.epa.gov/ejscreen. 8 Public Health Alliance of Southern California. Healthy Places Index (HPI) 3.0. 2022. Available at: https://www.healthyplacesindex.org/. 5/14 - Stadium - of Anaheim ark U) Overall Percentite I Ave Hill w ha Ave I Orange 'w CalEnviro5creen 4.0 Resu Its �40 pmg rl L Medic r°4 hapinan A�Fe �enterN r'. Alnl,:aikJ ..h.vt �I� ■ >80 90 c _ LaniPsan A- v—_ N,r I -_tram �� -__ >70 Odd ■ don Grave . ,, Garden Grove ��� } >S0 60 Fairhaven rulemarlal W' ® 0 5£t Task Avc— tea!+-- = �GardensGrawe.FWY r� Fa rk �0 E Santa ? I Clara Ave ■ :a30 4 L} E+istal Z ■ >20 30 ,0iirc,L,rA'var rala rke tplac T M +"'i 1 th SC rp , Santa An 47 Z: trr,l ■ �V) 20 _ College .3 14.11 e= ar'r'illawk'ick f+ z / _ i �, _. ... 0 10 (Lowest Scores) ■ cl '! '4'a� Ha rl Ave � Y � Golf Course Civic: Center DII.CIr � = .. ^r �--th St I }pv +,rf, . , Santa .gin San111Irl'if_I.t` ihP +r r+:} .. cn. �i tr, E I..In ',hi:.:(Av5 _ / ft ' {�.utin , :PP PI V, r'.'1rF�CIde A'rs _ CIO v) � q rl� t1' -i . Finch +, Golf Sulu a r� a� �: Santa Ana—, LL GS 2 -ter- F:1C F 11 II_I C n in'.'ry fir, avid L er Mer: half Course� � '! +rrd Edirig'r �IF5�r1 r{ hl+le �yuar~ R3ai,_-nal Par! A- f � E Edlrger Ave wide Square Regional Park ,ii SI r 17;7r ,S,r• P1 x f M i le sq ua re3)1 GO :aurae 1r'if, rn„ 14.��---__ r n e�_ _ Ur`Ave,- ' Warn FI P.. rr, o (0 E Dyer Rd E �Q i IbII A%fe Ln 55 AIG- n Ave �=' �. 7 ,. - - - '22 zj ku L0 s-Ave— v) } C` a+�rlcaa�Er►�.e w. The District • at Tustin Legac y w " - r �1s: - �Miesa Verde .� �� { � ° t kx' F'._ I r V. Country u_ _ 5 c r _ C 14+ b Bpi ke r St LI r� h n yC+ 7 4j�`{ i] a k x� , { Creek Gc e �rVa rle 33, ab 3� *a, n- AjWrt-Orang - "'a ti�aunty '? B; r yranga h Figure 1. OEHHA CalEnviroScreen 4.0, Santa Ana, CA. Overall Percentile of Exposure and Burden. In Figure 2, the EJScreen-measured traffic proximity is expressed as the counts of vehicles per day divided by the distance between the vehicle(s) and tract, providing a percentile rank for total exposure. The data included demonstrates the extreme disparity for these near -freeway Santa Ana tracts, the same tracts in the Northeast and Southeast of Santa Ana where hotels are primarily located, as these tracts already experience among the most extreme traffic exposures in the state and country (Figure 2, the traffic proximity expressed as traffic volume and distance and displayed as state percentile by tract). These already traffic -exposure overburdened tracts risk further concentration of traffic from increased hotel use and potential new hotels (further discussed in Section 7). Therefore, the congestion and traffic density increases may be more impactful to this already overburdened area. 6/ 14 WA91ilf RIM,- w i'xlEnvirotrorenental Burden Indic...®® � Yr�rl�a Linda Traffic Proximity (State Percentiles) bill 95 - 100 percentile 94 - 95 percentile 80 - 90 percentile 50 - 80 percentile Less than 50 percentile Data not available What does this mean? Ii Ainfin cOrm ear,l1 Rancho _ Santa Margarita r I_s'}aUrGsj i3eac'ii I i Figure 2. US EPA Environmental Justice Screening and Mapping Tool, Santa Ana, CA, environmental burden indicator of traffic proximity. The proposed STR could shift visitor accommodations in STRs from lower -burdened, dispersed residential areas to concentrated hotel zones in southeast Santa Ana, where pollution and traffic emission levels are already elevated. This shift in accommodation location could lead to increase vehicular traffic and hotel -generated emissions in an already -concentrated area facing significant air pollution exposure levels and health risks. Furthermore, the construction of more hotels in this area to meet the demands for visitors due to the STR ban could increase emissions from construction and additional operation to an area with higher burden. The relocation of accommodations could further the known pollution contributors to respiratory and cardiovascular health risks in these already overburdened communities. FM An STR Ban Would Increase Energy Demands Because Hotels Use More Energy Per Person Than STRs The proposed STR ban could cause visitors who would have otherwise stayed in STRs to stay in hotels, which consume more energy per person than STRs. Using CalEEMod, Ramboll modeled the operational GHG emissions of hotels and STRs for comparison. The single-family home CalEEMod land use type was used a surrogate for STR. Assuming an occupancy rate of 3 people per hotel room and 5.6 people per STR, hotels have much higher associated GHG emissions per person. It was found that hotels consume 7/14 M B dLL more electricity and natural gas per person than STRs, as shown in Table 2 and in the CalEEMod output in Appendix 13.9 TahIP 2 _ C)nPrafinnal FnPrnv l lqP nPr PPrgnn Land Use Electricity Natural Gas kWh/yr/person kBTU/yr/person Hotel 61773 13,974 Short Term Rentals 1,231 6,846 As a result of the increase in energy consumption when staying in a hotel instead of an STR, GHG emissions from energy consumption per person would increase by 179 percent. 5 An STR Ban Will Increase Fossil Fuel Usage In addition, increased VMT would require greater reliance on fossil fuels to power vehicle trips. Even with California's policies to shift the vehicle fleet towards cleaner cars and trucks, vehicle usage will continue to rely on gasoline for car and truck trips for years to come. The STR ban therefore results in greater reliance on fossil fuels, inconsistent with regional and state climate policy. The estimated fuel use is summarized in Table 3 and utilizes the same assumptions from Table 1. Additional calculation details can be found in Appendix A. 10 TahIP 'I_ Daily MnhilP Fiipl C'nncijmnfinn Land Use Gasoline Diesel Gallons per day Gallons per day Hotels 6,916 197 Short Term Rentals 1,272 36 Percent Increase with Hotel Use 444% 447% 7 An STR Ban Could Concentrate Traffic Resulting in Potential Noise and Health Impacts The potential ban of short-term rentals in Santa Ana could result in concentrated traffic on roadways going to hotels in the area, which could have noise and health impacts to the surrounding land uses. As described above, removing short term rentals as a means for lodging in Santa Ana would result in visitors needing to rely on hotels for their stay. Currently, there are over 20 hotels in the city limits of Santa Ana and over half of them are located in one concentrated area in the southeastern part of the City along Highway 55. It can be assumed that if more people will need stay in hotels instead of STRs, then the traffic to this part of town would increase significantly as it is likely all of this traffic would be concentrated to the roadways surrounding the hotel zone area. In comparison, traffic caused from 9 The CalEEMod analysis is based on 134 dwelling units, which is the amount of STRs that would accommodate the same number of people as a 250 room hotel. However, the energy use per person and percent increase in GHG emission is independent of the absolute number of short-term rentals in Santa Ana. 10 The fuel usage is based on 1,000 STRs in Santa Ana. However, the percent increase is independent of the number of short-term rentals in Santa Ana. 8/ 14 M B dLL visitors traveling to and from various STRs located throughout the City would result in more diversified traffic patterns as all visitors are not driving to one area. Furthermore, a potential new hotel constructed to meet the demand as a result of the STRs ban would likely be constructed in the area of Santa Ana with the majority of hotels, further concentrating traffic in this area. Health Risk Impacts from Traffic Ramboll performed a preliminary analysis that quantified the health risks from traffic emissions in order to assess the impact that increased hotel use in Santa Ana due to a ban on STRs could cause. A typical roadway with approximately 30,000 average annual daily trips (AADT) results in an excess cancer risk of 40 in a million at a nearby residential receptor."/12113 According to ITE, hotels generate 7.99 trips per day per hotel room.14 There are currently approximately 1,000 Airbnbs in Santa Ana, with other STRs also available. 15 Assuming this ban contributes to 950 more hotel rooms being used, traffic would increase by 7,560 vehicles per day, which results in health impacts that would exceed 10 in a million, which is the SCAQMD CEQA threshold of significance for cancer risk. This scaling approach also does not take into account increased truck traffic associated with deliveries to a hotel that would not occur to an STR. Therefore, banning STRs in Santa Ana could result in an increase in traffic on certain roadways that could be considered significant. If additional truck trips were taken into account, the number of hotel rooms that could cause an exceedance of the threshold of significance for cancer risk could be lower than 950 hotel rooms. It could be assumed that similar trends to cancer risk based on near -roadway traffic exposure would be true for particulate matter and toxic air contaminant emissions. Noise Impacts from Traffic Ramboll evaluated whether a potential traffic volume increase could cause a traffic noise increase that is considered either substantial (per CEQA guidelines) or increases the ambient conditions to a level above the Santa Ana General Plan Noise Element standard (65 dBA CNEL). Traffic noise analyses require specific knowledge of existing and future traffic volumes and vehicle mixes as well as project -related traffic volumes and mixes. In this case, this information is currently unknown. However, the following figure shows the current (2022) exterior levels of noise created by cars, trucks, or trains traveling along roadways and rail lines in the City. The City's noise and land use compatibility standards (see Table N-1) consider exterior levels above 65 dBA (CNEL) to be generally incompatible for residential and other noise -sensitive land uses. If residential or other noise -sensitive areas within the City that are currently below the 65 dBA CNEL level experienced traffic volume increases, specifically due to an increased hotel demand resulting from 11 Health impacts obtained from highway 152 from the Bay Area Air Quality Management District (BAAQMD) Mobile Source Screening tool at a distance of 100 feet from the roadway. This was used as a surrogate to estimate general health risks from only traffic. The traffic volume along this road was obtained from CalTrans. 12 Bay Area Air Quality Management District (BAAQMD). 2022. CEQA Roadway Screening Tool - Cancer Risk. Available at: https://data.bayarea metro. gov/Environment/CEQA-Roadway-Screening-Tool-Cancer-Risk/kz4a-ueki 13 CalTrans, Traffic Census Program. Available at: https://dot.ca.gov/programs/traffic-operations/census. 14 ITE. Trip Generation Manual 11th Edition. 15 https://app.airbtics.com/airbnb-data/united-states/CA/santa%20ana?payment-plan=pro&payment- duration=yearly 9/ 14 M B dLL the proposed STR ban, and the traffic volume increase caused the CNEL level to now exceed 65 dBA, the STR ban could be considered to have caused a significant impact. The magnitude of a traffic noise increase is dependent on several factors including the traffic volume increase, the vehicle mix, and the local site conditions. Based on standard methodologies prescribed by the Federal Highway Administration (FHWA) and considering a vehicle mix typical of suburban/urban areas, traffic volume increases would be expected to result in the following traffic noise increases. Project -specific detailed analysis, including a traffic analysis, would be required to further evaluate. Nonetheless, the volume increases listed below suggest the traffic increases likely necessary to increase the existing traffic noise conditions would need to be significant. As shown in the Figure below, the existing hotel stock is in the area near Highway 55 that is either already above the noise standard of 65 dBA or near the standard. Therefore, adding additional traffic to this area due to the shift to hotels as a result of the STR ban or the addition of new hotels to the area has the potential to exacerbate the existing noise impacts or create a new noise impact. Therefore, this should be studied in more detail. Figure 3. Contours from the Noise Element. Source: Noise Element, Santa Ana General Plan, Final, April 2022. 10/14 M B dLL Table 4. Noise Impact from Traffic Increase Traffic Volume Increase Potential Traffic Noise Increase 25% 1 dB 50% 2 dB 100% 3 d B 8 Elimination of Short -Term Rentals Could Cause the Construction of New Hotels to Meet Demand; the Construction of New Hotels Would Result in Numerous Environmental Impacts That Require Studying As detailed in the Ramboll memorandum ""ECONOMICS ANALYSIS OF SHORT-TERM RENTAL REGULATION", the prohibition of STRs, including those currently operating within the City, could compel tourists to seek alternative accommodations, increasing demand for hotels and potentially leading to the development of additional hotels as a reasonably foreseeable consequence of the STR ban. The construction of hotels has impacts on the environment that have not been studied. In particular, construction of hotels has potential noise and air quality impacts as discussed below. Potential Hotel Construction Air Quality and Health Impacts Resulting from STR Ban Ramboll performed a screening health risk assessment to determine the potential cancer risk resulting from construction activity of a hypothetical new hotel. The emissions associated with the construction of these hotels encompass on -site, off -road heavy equipment, off -site, on -road vehicle travel, architectural coating, paving, and fugitive dust. Ramboll utilized CalEEMod to estimate construction emissions from a 250-room hotel as shown in Appendix B, which is an average mid -size hotel. Ramboll used an existing hotel project site to model emissions in AERMOD as a surrogate for the space of hotel construction. Concentrations resulting from diesel particulate matter (DPM) emissions from off - road construction equipment in CalEEMod were modeled on receptors in a grid of 20 meters. The health risk assessment used default exposure assumptions for residents as outlined by OEHHA.16 As indicated in Table 5, the construction of a hotel without emissions mitigation results in an excess cancer risk of 48 in a million for the maximum exposed individual (MEI), which exceeds the SCAQMD's threshold of 10 in a million. Cancer risks continue to exceed the threshold until a distance of 450 feet from the construction area. Table 5. Cancer Risk from Hotel Construction Source Cancer Risk (in a million) Construction of a 250 room Hotel 48 SCAQMD Threshold of Significance 10 Potential Hotel Construction Noise Impacts Resulting from STR Ban Construction of structures generates noise, which is regulated by the City of Santa Ana. 16 OEHHA. 2015. Air Toxics Hot Spots Program. Risk Assessment Guidelines. Guidance Manual for Preparation of Health Risk Assessments. February. 11/14 City of Santa Ana Noise Element California Government Code encourages each local government entity to implement a noise element as part of its general plan. In addition, the California Governor's Office of Planning and Research has developed guidelines for preparing noise elements, which include recommendations for evaluating the compatibility of various land uses as a function of community noise exposure. The City of Santa Ana has established a Noise Element as part of the Santa Ana General Plan.17 The Noise Element works to ensure that the City limits the exposure of the community to excessive noise levels in noise -sensitive areas and at noise -sensitive times of day. Specifically, the City has established standards for noise levels (Community Noise Equivalent Level [CNEL], dBA) for land uses as displayed in Table N-1. Additionally, all residential uses should be protected with sound insulation over and above that provided by normal building construction when constructed in areas exposed to greater than 60 dBA CNEL. Sound levels resulting from a project that exceed the standards listed in Table N-1 or that cause the existing conditions to increase above these standards would typically be considered to be impacting the surrounding community. TABLE N 1. INTERIOR AND EXTERIOR I E STANDARDS Cateecries " Use Cat e-gones I nterio' Exterio r' i r.� le-fri d u p Iex m u I t- f�mil� r 45 dB CNEL51 65 dB CNEL I r istitutiinna Hospital, school classroom/ 45 dB CN EL 65 dB CNEL pal ayg rou n d Religious facility, library 45 dB CN EL - Open �p f Pa r k5 -- 65 dB -CNEL Notes 1. 1 r terior areas, to incl A el. h u t not Ii rn tad to bed roar n s, ha thtiroo ms, k itch-e ns, I iw ing morns, di ni r~ g roo r ns, a riva�e offic-es, and conference morns 2. Exteri or area s shal I mea n _ p rivate ya rd s of s-ngle fa mi ly ho rr es, pa rk plicn is a reasr school playgrounds, COMM on area P rivr3tie operi Spa cei 5uch as atriL,ms rorl ba lconie5, 0,aII be excluded from exterior noi�,N requirements p rovided s u ff islent cocamon area is irr-cl u ded with in the p roject. 3. 1 rater o e noise I aval eeq u i re meats assurin a a r-1 osad-w ind Dw ca n di don. M Pchan ical oe nti latio n syste rn c ; at el-r r i-gans (a- nal u ra l venti ladon s h a 11 be provi ded per Ch a pte r 12 of the U r iform Bu it c i r & code, a s necessa ry Figure 4. Noise Standards from the Noise Element. Source: Noise Element, Santa Ana General Plan, Final, April 2022. City of Santa Ana Noise Ordinance The City of Santa Ana regulates noise emissions via the Santa Ana Municipal Code, specifically Chapter 18, Article 6 (Noise Control).18 The noise ordinance establishes that it is unlawful for any person at any location within the City of Santa Ana to create any noise, or to allow the creation of any noise on property owned, leased, occupied, or otherwise controlled by such person, which creates a sound level 17 https://www.santa-ana.org/documents/april-2022-general-plan-noise-element/ 1s https://library.municode.com/ca/santa_ana/codes/code_of ordinances?nodeId=PTIITHCO_CH18HESA_ARTVINOC O 12/14 M B dLL at a residential property that exceeds the following exterior noise standards. The noise levels are based on a cumulative period of more than 30 minutes in any hour. Table 6. Santa Ana Noise Ordinance Eloise Zone Noise Level Time Period 1 55 dB(A) 7:00 a.m.-10.00 p.m. 50 d B(A) 10:00 p,1-9.- 7:00 a.m. Source: Santa Ana Municipal Code, §18-312. Noise emissions from one property that propagate onto an adjacent or nearby residential property and exceed these limits are deemed to be noncompliant with the Santa Ana Municipal Code. Noise emissions related to construction activities are exempt from the limits, provided the construction activities do not occur place between 8:00 p.m. and 7:00 a.m. on weekdays, including Saturday, or at any time on Sunday or a federal holiday. Analysis of New Hotel Construction The effect of construction noise impacts on nearby noise -sensitive neighbors is dependent on the location and nature of the construction activities. Depending on the construction activities and neighboring land uses, there is a potential for possible significance threshold exceedances related to the resulting construction activities, particularly in relation to residential communities. While noise from construction activities is exempt from the Santa Ana Municipal Code during daytime hours, noise from construction activities occurring during the nighttime hours (as detailed in the previous section) must comply with the established limits. Additionally, the potential for substantial temporary increases to the existing ambient conditions could be considered relative to CEQA guidelines. Construction typically involves the use of heavy machinery that can be a significant source of noise and, while often temporary, can result in significant impacts. Construction equipment commonly includes air compressors, backhoes, concrete trucks, cranes, dump trucks, excavators, graders, pavers, tractors/dozers, vibratory rollers, portable generators, and water trucks. Depending on the phase of construction, project construction typically involves a combination of these types of off -road and portable construction equipment. Assuming a typical construction plan, common types of construction equipment, and typical construction equipment sound levels published by resources such as the U.S. Federal Highway Administration, the Federal Transit Administration, and manufacturers, potential overall sound levels can be estimated. Accordingly, construction sound levels could range from approximately 75 to 90 dBA assuming typical receptor distances of 500 ft to 50 ft. Construction activities also may need to occur at night due to various limitations. Examples include concrete pours that need to occur when other construction is not happening or would impede traffic, accelerated construction needs to meet hotel demand that may come with the Olympics in 2028, roadway construction work that needs to occur at nighttime. The table below outlines general construction phasing and equipment assumptions employed to estimate approximate sound pressure levels (SPQ for common construction phases for a hotel use as generated in CalEEMod.19 It is anticipated that these sound pressure levels are above typical 19 California Air Pollution Control Officers Association (CAPCOA). California Emissions Estimator Model (CalEEMod®), Version 2022.1. Available online at https://www.caleemod.com/ . 13/14 suburban/urban ambient sound levels and therefore could cause a temporary increase above the threshold discussed above. For reference, typical suburban/urban background sound levels are commonly on the order of 45 to 55 dBA during daytime hours and lower during nighttime hours.20 Because sound pressure levels from construction of a new hotel, which was needed due to a STR ban, have the potential to cause a temporary increase above the noise level threshold, more analysis is needed to evaluate specific impacts and potential mitigation. While construction may be exempt from the noise ordinance during daytime hours, the table below shows that the construction could have a significant noise impact on the community. Furthermore, if any nighttime construction activity is needed for the hotel, the noise levels below show that threshold for nighttime work in the noise ordinance would be exceeded. Table 7. Noise Impacts from Construction Activity Avg. Usage Equip Lmax Acoustical Equip Total Total Total Construction Size, SPL @ SPL @ SPL @ SPL @ Equipment Type Qty Hours SPL @ Use Phase per Hp 50 ft Factor 50 ft dBA 50 ft dBA 50 ft dBA 500 ft dBA Day dBA Rubber Tired Dozers 3 8 367 85 40% 81 86 Site Tractors/Loaders/Bac 4 8 84 84 40% 80 86 Preparation 89 79 khoes Excavators 2 8 36 85 40% 81 84 Graders 1 8 148 85 40% 81 81 Rubber Tired Dozers 1 8 367 85 40% 81 81 Grading 90 80 Scrapers 2 8 423 85 40% 81 84 Tractors/Loaders/Bac 2 8 84 84 40% 80 83 khoes Cranes 1 7 367 83 16% 75 75 Forklifts 3 8 82 75 40% 71 76 Generator Sets 1 8 14 82 50% 79 79 Building 87 77 Tractors/Loaders/Bac Construction 3 7 84 84 40% 80 85 khoes Welders 1 8 46 74 40% 70 70 Pavers 2 8 81 85 50% 82 85 Paving Equipment 2 6 89 85 50% 82 85 Paving 89 79 Rollers 2 6 36 85 20% 78 81 20 U.S. Environmental Protection Agency, Community Noise, December 31, 1971. 14/14 APPENDIX A VMT ANALYSIS Confidential O O o N � O U E L N � 0 C G =O a O W O C x o O O a O i O o o � O O U � �7 O �+ o O ry-) FBI Z 4 C U U o a O > Ln G \ O 00 O Ln G o, Ln rn •i \ Ln \ Ln rn M N a U Vl _ C O CO CO ,L lU CO H �E O > U O O p, O- Ln Ln O � a � E D g O f� O �O = O co a O ^ GC G W H 0 I'D O a ao L d a) 'G L- N O O CC = J U) E O C •cn (B (B (n o O E Q) o > Q cp O Q N U O O O L U U 4 W O ca O" Q = E DC rB L .� U U ca _c_- _ a--) Q) L L O O Q a--) E L E E Q) L o 0 0 a)�) U O OL O L 4-) Q) O Q) O - Q) -a E 3 Zn O E ro �-1 O E O () Q) O cn Q) u M E UL- Q) M L U L L (u O uj Q Q ) L E N ra L I ^ Q) > > 0) L C cn � M CL � V) Q E �_ •L Q -W O 0 x L Q) L L .0 () E Q) 0 c O Lno > (D �M Q) O Q (� O >L L U O a--) Q) a--) _0 UCC)Z a) O I LnQ T--I a--) M a--) M U . V) C ) Q) L 0) 0 (n 4••) ro U cn O" _� O Q) cB 0 4-) O Q O Q Q) M U L L Q) M M M Q O-0C (n Ln C L O N U ^ a--) a--) ca O V O E O •L M a--) L -_ Q L Q) Q) O O � CL C � -O >` Q) ca rB M c) Q) �_0 O Q J 4 >� U 3 O E ra Lu M a) E) -O U CL � Q) � U rB C 4�-) Q) 3 O 2 4' 4 C C 0) Q) Q) - - O -p �) 4-) �) ) LJ N 3 Q L O cn E O 3 �' Q) Q c N L- Q) CL O 0) -0 -0? C .� L L O Q) Q) U O o O" J E > ra rB L _c_— L LJ L O Q) (n > > L Q) -uw L L E o Q) � m c -a = 3 aU �, O O - cn U L N O w rB a - O O -c-- LJ C • L Q) N ,--i a••) LJ O 4-+ > cn U Q) OL � a) U `- ra E a) Q E ro m o ca 0 00 Q L Q Q LJ Q) Q m �O � � U 0) C L Q) c 4-d a Q ra LJ ro� C Q to Q) > CL i = Q) Q) Q) p 6 -E U -1 Q) N cn m 'IT Ln 1,o � un c C O Q) U > U C C Ln 0, Q) L- O E � _N a-d U_ O T Ln O > I I I U cn > > L QL Q) a-d Q) E c � �. O N L 0 U O z u + Ln E O N O M M O Q) Q Q) L L O O �) Q U ro E E E ro O O -w 70 x O Q) U 0) U L m m % Q Q I I � I Ln I 0 X N i X O O z a a (A Q) CO G � O Q) M Q) E E v 0) c Lu L„ Lu Q) o O 4J cB > c1 E a LJ Q) c� Q) x L LO O X `-- o '0 o U E O I 0O � rB 0 L O U > 2: 1 H LJ LLU I Q) ra O O ~w Q U U U Q) U C Q) L Q) Q) M Q) M M > Q Appendix Table A2: VMT and Fuel Consumption Comparison of Short Term Rentals and Hotels Fuel Consuption2 Fuel Percent of Fleet'f2 (gallons per mile) Gasoline 95% 0.055 Diesel 5% 0.031 Land Use Peak Daily VMT3 Gasoline Consumption Diesel Consumption (miles/day) (gal)4 (gal)4 Short Term Rental 241101 11272 36 Hotel 131,086 6,916 197 1 Gasoline includes gasoline fueled vehicles and plug-in hybrids. Natural gas is excluded from this analysis due to the negligible VMT from natural gas vehicles. 2 The fleet mix and fuel consumption per mile is determined using EMFAC2021 for Santa Ana in 2027. The fuel consumption rate is weighted based on fleet type. 3 The number of peak daily VMT were determined in Appendix Table Al. 4 Gasoline and diesel consumption are calculated by multiplying the VMT by the fuel -specific percentage and then by the weighted fuel consumption factor (gal/VMT) derived from EMFAC output. AhhrAxiiafinnc STR - short term rental VMT - vehicle miles traveled gal - gallon References: California Air Resources Board (ARB) 2021. EMFAC2021. Available at: https://ww2.arb.ca.gov/our- work/programs/mobile-source-emissions-inventory/msei-modeling-tools APPENDIX B CALEEMOD REPORTS Confidential N O N C'7 L O QL CCU ry CU CU CU a--j O no L 0 U (U U) U) O_ ' U) .� E cn O }' C6 O m L O 4-0 L0' UQL U) m � O � E p _,_, U 0 0' cn m CZ > N W cn cn CU U4-0 CU � '0 cn .cn E U CO C'i E cn C= p 'cn E W � � � ca 0)'� CU L E O U cn � .O cn •— W c: O � cn C= U N CU �_ � cn � .O c •— W C= O � cn c U N N _ O cn 4-0 cn �_ '� Q L � O U cn C= •p cn E W cn 4-0 L CU O N � � 0 C/) >1 -0•-• cn C: •p cn E W cn -&-1 L CU O L6 N cn • a� 0 cn O . 0 W 0 4-0 U cn O U c N CN (6 ca CU C/)a) CM 4-a � O Cv (6 M Cyi N }' ca E O N O N O U 4-0 cn c O Li Cyi N }' ca 0) E ti N O O U 4-0 cn c O Il� Cyi F N C'7 N, m N O N C'7 L O QL CCU ry CU CU (U a--j O no V fl [V .E i [V cn J In cn O .U) .cn E W �U U W N \1 [V .E D i [V cn D J In cn C= O .cn cn .E W cn C� Z C'i N - A c� E D co \1 CV cn D cn .cn .cn E W L c� E D [V cn .O cn .cn E W U) m c� E D \I 0 cn D J cn O .cn .cn E W 4-0 C6 L Ti m4w , c� E D \I \1 r0 N O N C'7 L O QL CCU ry CU CU CU a--j O no 00 ►i m�0 ►i CU 4-0 .E I (n •U CU Cf) cn C= O .cn .cn E W a� L cn a� CS 0 C/) ca CU 0 Q C'i O ►i m 0 U i _N � CU cn • U U) 4 •QL ( Q) > 4-0 0 (D c E 4-0 (n E cn U O I O CU U O C\i U > C\j C� ui L6 L6 ui u Q ui ui w N O N C'7 L O QL tea/ ry Q) Q) a--j O no U) CU Q) L V ) 0 L O U 0) 0 E L c� W O cn L O u1 1-1 hIN U ti L6 cn L O U H O .cn cn .E W m O 4-0 0- E cn U •U U _N W O U L 4-0 cn O 0 2 0 v� � — L � }' �'zzL to U O CO4-0 Q (6 O cn (6 0 o U 4-0 ._ cn - ca cn U (6 O 4-0 CU O N co O O ui O O 0 6 6 L6 L6 u � ui L6 L6 C= O E cn O U L a� cn c� c� L O CU 0 M, ca N M, N O N C'7 L O QL ACV ry CV CV CV a--j O no ui ui U �0 Cf) L 0 Cf) co cn 0- E :3 n L H C- m cn L O U CU E W L6 M, L O U cn U) m E .O m C6 ui C= O L cn CS 0 Cf) N C6 M, E U C9 L E E cn ca U Lf) LO m M, M, N O N C'7 L O QL CCU ry CU CU 0 (U a--j O no Cu 0 W CU 2 C/) O U 0 0cz C/) CV O � cn U) L- 0 C/) 4 .� 06 4-0 _ C/) cn -� L O O CU O U) � 06 > U >1 = O 4-0 = 4-0 w' _ N co co ti ti ti ti ti ti av, W N O N C'7 L O QL C�CU ry CU CU p (U a--j O no � I • O ' U) U) 0 rrMr� Q w V (n p M M D L L Q O O • O Q O U - - n ) U U 0') O c� M M M N c4 U) O O N � I Q Q U U O C) 4 • N I� N � � � � O N N O C4 M O� N O p L O co M L M O O O-) O O p • 2 N I U N (� O 0 0 0 U-) ti 0 N ' • O O • O M CM • O CM N O �+ E M O E O L. 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This report was completed Stefanie O'Gorman, an environmental economist with 23 years experience in her field. Stefanie specializes in the integration of costs and benefits within decision making and has worked across the spectrum from policy design and development to project and infrastructure delivery. She has acted as an expert witness in a number of planning related enquiries in the UK and Ireland relating to water regulation, marine infrastructure planning and Ramboll transport related projects, focusing on the economic and socio-economic impacts 250 Montgomery St., of these developments. Suite 1200 San Francisco, CA 94104 US USA eDUCATION/QUALIFICATION MSc Ecological Economics, University of Edinburgh, 2001 T+1 510 655 7400 BA (Mod) Natural Science, Trinity College Dublin, 1999 F+1 510 655 9517 https://ramboll.com Based on professional experience and judgment, this analysis assumes a reasonably foreseeable potential that: 1. A ban on STR will spur new hotel development and, as a result of increased demand on local hotels, local hotel availability will go down and room rates will go up. 2. Result of (1), people will be forced to travel further to find available or affordable hotel rooms. Theses assumptions are found to be sufficiently supported by evidence or that insufficient evidence is available to reject them, as outlined here. Introduction Santa Ana, the largest city in Orange County at 27.2 square miles and home to nearly 328,000 residents', is a rich cultural, culinary, and entertainment hub with deep historical roots. As the county seat, it 1 https://www.oranciecounty.net/cities/SantaAna.html 1/5 blends vibrant city life with a preserved historic core. Visitors can explore a variety of attractions, from the art -filled streets of the Downtown Santa Ana Artwalk to the Bowers Museum's global collections and the Discovery Cube's interactive science exhibits2. The city's distinctive neighborhoods offer everything from historic architecture to innovative food markets, and the popular Frida Cinema and Yost Theatre. Tourism is a cornerstone of Santa Ana's economy, driving substantial revenue and job creation for the community. In 2023, visitor spending alone contributed an impressive $414.7 million to the local economy3, an increase of over 9% compared to the previous year. This spending supports local businesses and fuels sectors like food service, accommodations, retail, arts, and transportation. Food service alone saw $109 million from visitor spending, with accommodations adding another $107 million, and arts, entertainment, and recreation generating $81.5 million. These visitor expenditures provide essential funding for city services like public safety, parks, and neighborhood improvements, while also alleviating the tax burden for residents —without tourism -related tax revenue, each household would pay an additional $195 annually in local taxes. Tourism's impact on employment is equally significant, supporting nearly 3,000 jobs in Santa Ana and contributing around $137 million in wages to the local workforce. With continued growth in overnight visits and local attractions, tourism remains a vital industry that helps sustain the community's economic well-being and enhance residents' quality of life. 1. How a ban on STR could spur new hotel development and impact demand and room rates Orange County's STR occupancy was 72% on a year-to-date basis and RevPAR was $151 and its hotels also maintain a high 77% occupancy rate and an ADR of $196.59, which underscores the region's strong demand. High occupancy figures are seen in all months - with only January falling below 70%. Orange County's hotel room demand showed a 5% year -over -year growth, highlighting its popularity within the state. Based on AirDna data, Santa Ana's appears to have or had up to approximately 2,180 STR listings (approximately 79% of which are Airbnb listings), with a current occupancy rate of 53%. This is approximately 73% for Airbnb rentals, for which there appear to be approximately 1,1004 active STR listings.5 STRs generate substantial revenue for hosts (estimated at $43,000 annually per host for Airbnb rentals)6 with an Average Daily Rate (ADR) of $237.37. 2 https://www.visitcaIifornia.com/places-to-visit/santa-ana/ 3 https://www.travelsantaana.com/about-travel-santa-ana/economic-impact-of- tourism/# : N:text=In%202023%2C%20traveler%20expenditures%20from,in%201oca1%20and%20state%20tax es. 4 https://www.santa-ana.org/short-term-rentals-ban/ 5 We note that even if the exact amounts of STRs in the City are slightly higher or lower than the approximate values shown here, the conclusions of this report remain consistent regarding the impact of the STR ban on spurring hotel demand and forcing individuals to forced to travel further to find available or affordable hotel rooms. 6 https://airbtics.com/annual-airbnb-revenue-in-santa-ana-california-usa/ 7 https://www.airdna.co/vacation-rental-data/app/us/california/santa-ana/overview 2/5 Accurate data on the size of the whole lodgings market in Santa Ana is not readily available for review, however the number of listings for hotels and motels on www.booking.com and Expedia is not significant, at less than 100. The majority of these properties are 3 star or less. If we assume that the rate of hotel /motels to STRs in Santa Ana is representative of that of Orange Country where the hotel room supply is 61,937 (see table below) and the number of STRs is 10,8418, then STRs would represent 15% of the lodging supply in Santa Ana. However, given the < 100 hotels found online, is it considered likely that STRs contribution a significantly higher percentage of the lodging market locally. Forecast summary: Annual, Orange County Levels 2019 58,282 45,141 77.5% $161.94 $125.42 $2,668,166,801 2020 50,463 221479 44.5% $136.03 $60.59 $1,116,070,720 2021 56,897 32,999 58.0% $167.45 $97.12 $2,016,885,289 2022 60,995 42,663 69.9% $177.02 $123.82 $2,756,556,935 2023 61,590 45,366 73.7% $185.82 $136.87 $3,076,862,904 2024 61,937 471723 77.1% $196.59 $151.48 $3,424,409,154 Growth 2020 -13.4% -50.2% -42.5% -16.0% -51.7% -58.2% 2021 12.7% 46.8% 30.2% 23.1% 60.3% 80.7% 2022 7.2% 29.3% 20.6% 5.7% 27.5% 36.7% 2023 1.0% 6.3% 5.3% 5.0% 10.5% 11.6% 2024 0.6% 5.2% 4.6% 5.8% 10.7% 11.3% Relative to 2019 2020 87% 50% 58% 84% 48% 42% 2021 98% 73% 75% 103% 77% 76% 2022 105% 95% 90% 109% 99% 103% 2023 106% 100% 95% 115% 109% 115% 2024 106% 106% 99% 121% 121% 128% Source: STR; Tourism Economics The minimum stay durations data for short-term rentals in Santa Ana varies. AirDna data suggests that half of the stock has a minimum stay of under 30 days. This data appears to be 2023 data and to relate to their estimate of 2,000+ STR listing in that data source. Therefore, it is not possible at this stage to tell how many of the City Council estimated 8 https://www.keydatadashboard.com/en-gb/markets/orange-county-california 3/5 1,100 listings would be impacted by designated for shorter stays, but it could be as high as 100%. STR Listings by Minimum Stay in Santa Ana 0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% ■ 30+ Nights ■ 7-29 Nights ■ 4-6 Nights 3 Nights ■ 2 Nights ■ 1 Night Source: https://www.airdna.co/vacation-rental-data/app/us/california/santa-ana/overview With STRs accommodating a significant portion of the lodging market, their removal would leave a considerable gap in available accommodations, which the existing hotel infrastructure is unlikely to be able to fully absorb given Orange County's occupancy rates were already at 77% in September 2024 (California Travel Forecast - October 2024). Effects of a Ban on STR on Local Hotel Demand, Room Rates, and Availability Eliminating STRs is likely to intensify demand for hotel accommodations, which would reduce availability and drive up average daily rates (ADR). Orange County's ADR is already high, at $209.14 (see table below) (192$ in Santa Ana9), and Santa Ana's hotel market is part of this broader region where occupancy and room rates reflect high demand, particularly near attractions. With STRs contributing substantial capacity, the ban would further stress local hotels, as noted above likely leading to increased ADR due to scarcity. The 7.1% year -on -year increase in Revenue Per Available Room (RevPAR) in Orange County indicates a strong market with limited room for new capacity; hence, shifting demand from STRs to hotels would almost certainly lead to higher room rates, potentially pushing them beyond the reach of budget -conscious travelers. Short Term RentalsSeptember Occ % ADR RevPAR 2024 2023 2024 2023 2024 2023 California 68.0 68.4 190.57 192.15 129.60 131.41 Orange County 72.1 72.0 209.14 210.91 150.74 151.91 9 https://rabbu.com/airbnb-data/santa-ana-ca * httgs://www.airdna.co/vacation-rental-data/app/us/california/santa-ana/overview 4/5 2. Travel Displacement and Need to Seek Affordable Lodging Elsewhere: Rising hotel rates and limited availability could push some visitors to look for more affordable accommodations in nearby cities. With the increased demand and rising prices in Santa Ana's hotel sector, neighboring areas like Anaheim or Irvine may absorb some of the overflow but would also likely experience upward rate pressure, creating a ripple effect across Orange County. Given that Orange County's occupancy was 72% on a year-to-date basis and RevPAR was $151 and shows high occupancy figures in all months - with only January falling below 70%, hotels in adjacent areas to Santa Ana are likely to be at full capacity during peak seasons, especially July10, or major events. As a result, tourists may find themselves traveling farther for budget -friendly lodging, potentially discouraging some visitors from choosing Santa Ana altogether. In addition, group room demand in California was up a robust 7% relative to September 2023. Orange County saw this increase by 35% year on year for the month of September 202411. This strong local growth in demand is reflected by the fact that approximately 650 of the AirBNB listing in Santa Ana are for 2+bedrooms, so suitable for grouPS12. The loss of this accommodation type may not be easily substituted within the existing local supply, which could, as a result, spurn additional local development. The available evidence and analysis allows a reasonable conclusion to be drawn that in the short term visitors will be pushed away from Santa Ana due to occupancy restrictions and increased rates, and in the longer term these constraints could result in new hotel capacity development. 10 https://rabbu.com/airbnb-data/santa-ana-ca 11 https://industry.visitcalifornia.com/research/report/monthly-travel-indicators-summary 12 Santa Ana, Airbnb Market Statistics & Data, United States 5/5 Ibarra, Evelyn From: Thoa Tran < Sent: Tuesday, November 19, 2024 8:22 AM To: eComment Subject: Public Comment -City Council- Nov 19, Agenda Item #35 Attention: This email originated from outside of City of Santa Ana. Use caution wnen opening attachments or links. Dear City Council Members of Santa Ana, We are writing to express our strong support for the proposed ordinance to ban short-term rentals (STRs) in our city of Santa Ana. The short-term rentals have caused many problems in our city: excessive noise, parking problem, degradation of the neighborhood's residential character, trash, and many more issues. Many families have a very difficult time buying a home partly due to the homes being snatched at high prices by investors for short-term rental purposes. We have seen many homes being bought at high prices by investors to do short-term rentals that have caused so many problems for the families who live in the neighborhood. Please continue to support the ordinance banning short-term rentals and protect the families who are living in Santa Ana. City Council Members of Santa Ana, may you be greatly blessed for supporting the ordinance of banning short-term rentals and protecting the Santa Ana families Sincerely, Thoa Tran and family Ibarra, Evelyn From: Rick Nguyen < Sent: Tuesday, November 19, 2024 8:33 AM To: eComment Subject: Public Comment --City Council --Nov 19th, Agenda Item #35 Attention: This email originated from outside of City of Santa Ana. Use caution wnen opening attachments or links. Dear City Council Members of Santa Ana, We are writing to request your support for the proposed ordinance to ban short-term rentals (STRs) in the City of Santa Ana Short-term rentals have caused many problems for us and for the families in the city of Santa Ana. Some of the problems include but not limited to parking problems, excessive noise, trash, undermining the integrity of our neighborhood, and many more issues Thank you for supporting the ordinance banning short-term rentals and protecting the well-being of Santa Ana families over the profit -driven interests of STR investors. Sincerely, Rick Nguyen and Family 1 Ibarra, Evelyn From: Diane Tholin < Sent: Tuesday, November 19, 2024 9:19 AM To: eComment Subject: Public Comment City Council- Nov 19th, Agenda item #35 Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Re: Short term Rentals I urge you to support the ordinance to ban STRs so that we can protect the long term well being of Santa Ana families and neighborhoods over the profit driven interests of STR investors Thank you. Diane Tholin 1 Ibarra, Evelyn From: ceo4dds < Sent: Tuesday, November 19, 2024 9:31 AM To: eComment Subject: Public comment- Nov 19 Agenda item #35 Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Santa Ana City Council, As president of Casa de Santiago I strongly recommend council supports the ordinance banning short term rentals in Santa Ana Thank you, Joanna Peterson CDS President Sent from my Verizon, Samsung Galaxy smartphone 1 Ibarra, Evelyn From: ceo4dds < Sent: Tuesday, November 19, 2024 9:32 AM To: eComment Subject: Public comment- Nov 19 Agenda item #35 Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Santa Ana City Council, As president of Casa de Santiago I strongly recommend council keeps the ban on limited rentals. Thank you, Joanna Peterson CDS President Sent from my Verizon, Samsung Galaxy smartphone 1 Ibarra, Evelyn From: Karen OCallaghan < Sent: Tuesday, November 19, 2024 10:16 AM To: eComment Subject: SA Council Mtg 11/19/24 - Public Hearing Agenda Item #35 re: STR Ordinance Attention: This email originated from outside of City of Santa Ana. Use caution wnen opening attachments or links. Dear Santa Ana City Council Members, As a 35-year resident of Ward 3, 1 urge the SA City Council to, once again, thoughtfully consider the issue of banning Short Term Rentals (STRs) and conduct thorough research before making a final decision. Many local hosts started operating to supplement their income, helping them remain in their homes. According to AirDNA, 81% of STRs in Santa Ana are small properties with two or fewer bedrooms. It's important to differentiate between small, owner -occupied hosts and absentee owners who use property management companies to run their STR. While I understand concerns about the housing shortage, I doubt that STR units can significantly impact permanent housing, as most are one- or two -bedroom units inside or attached to existing homes. Santa Ana is missing out on a significant revenue opportunity. By implementing a Transient Occupancy Tax (TOT) and permitting on STRs, as many other cities have done, our city could generate much needed additional funds. This revenue, combined with the economic boost from STR guests spending money at local restaurants, shops, and services, could be used in other areas of need within our city. Furthermore, these funds would help provide the resources to swiftly enforce existing regulations and issue fines for noise, parking, and occupancy limits, maintaining our peace and safety. In closing, I urge the Council to carefully consider these nuances instead of approving a 'blanket' ban on STRs. Let's find a balanced solution that helps responsible hosts, generates city revenue, preserves our neighborhoods, and fosters our local economy. Thank you, Karen O'Callaghan Ibarra, Evelyn From: Tim Nguyen < Sent: Tuesday, November 19, 2024 11:35 AM To: eComment Subject: Public Comment - City Council - Nov 19th, Agenda Item #35 Attention: This email originated from outside of City of Santa Ana. Use caution wnen opening attachments or links. Dear City Council Members of Santa Ana, I am writing today to strongly support the proposed ordinance to ban short-term rentals(STRs) in our city. I have been a resident for 20+ years and have found STRs to only take from our community and not add to it. With STRs I have observed that: • Guests are not considerate of their neighbors, being loud and often throwing parties • When an issue arises, no one seems to take accountability between the guests, investor or even AirBNB to address issues. • The investors/owners of these STIR properties are not from our city and are only looking at lining up their pockets with little consideration for development of our community • We are reducing the amount of homebuyers who want to make Santa Ana their permanent place of residence and add value to our neighborhoods In the interest of our city and local community, I strongly urge that we ban all STRs effective immediately. Thank you, Tim 1 Ibarra, Evelyn From: Stephanie Feher < Sent: Tuesday, November 19, 2024 12:52 PM To: eComment Subject: City council meeting agenda item Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. I am in support of item 35, and I support banning short-term rentals in ward 3. Thank you, Stephanie Feher, homeowner, Ibarra, Evelyn From: Maura O'Neill <maura@betterneighborsla.org> Sent: Tuesday, November 19, 2024 1:01 PM To: eComment Subject: Public Comment Letter on Agenda Item #35 Attachments: Better Neighbors LA Comment Letter - Agenda Item 35 Support.pdf Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Hello, Attached, please find my comment for the written record on agenda item #35, Public Hearing — Conduct a First Reading and Adopt Ordinance Amendment (OA) No. 2024-04 Repealing and Reenacting in its Entirety Article XXI to Chapter 8 of the Santa Ana Municipal Code (SAMC) Prohibiting Short -Term Rentals (STRs), and Adopt Enhanced Fines for Violations of the Short -Term Rentals Ordinance. This is in support of the adoption of the ordinance to prohibit short-term rentals and adopt enhanced violations for fines. Thanks, Maura O'Neill she/her Policy Analyst and Advocate Better Neighbors LA (213) 355-7475 maura@betterneighborsla.org 1 0 Wer ° �m IaME 1 Eel 59101 November 19, 2024 City Council City of Santa Ana 20 Civic Center Plaza Santa Ana, CA 92701 eComment( santa-ana. org Va Electronic Mail UNITE HERE! LOCAL 71 Re: Better Neighbors LA Comment Letter —November 19, 2024 Hearing Agenda Item #35: Ordinance to Repeal And Re -Enact in its Entirety Article XXI to Chapter 8 of the Santa Ana Municipal Code (SAMC) Prohibiting Short -Term Rentals (STRs) and to Adopt Enhanced Fines for Violations of the Short -Term Rental Ordinance —SUPPORT Dear Councilmembers, Better Neighbors LA writes to you in support of adopting the Ordinance Amendment (OA) No. 2024-04 that will repeal and re-enact in its entirety Article XXI to Chapter 8 of the Santa Ana Municipal Code (SAMC) prohibiting Short -Term Rentals (STRs) and adopting enhanced lines for violations of the Short -Term Rental Ordinance. As residents across Southern California continue to face a housing affordability and homelessness crisis, precautions must be taken to protect housing stock for long-term residents. It is crucial to codify Santa Ana's prohibition on short-term rentals within the City, and in the process, further safeguard housing for long-term residents. Better Neighbors LA is a coalition of hosts, tenants, housing activists, hotel workers, and community members working to curb illegal short-term rental activity with the intent to protect housing and neighborhoods impacted by the short-term rental industry.' We conduct data analysis and research on the short-term rental industry and its impact on affordable housing. According to our analysis of AirDNA data, the vast majority of short-term rentals in the City of Santa Ana are unhosted, meaning they are whole home rentals that are not primarily used for long-term housing, unlike hosted rentals.2 Since 2019, the number of unhosted short-term rental listings has increased by 294% and grown to over 509 units. Hosted units, on the other hand, have risen by 169 listings, or 134%. The number of unhosted STRs aligns with the staff report findings on enforcement notices and citations. Staff identified that the majority of properties with I https://www.bettemeighborsla.ory/ 2 AirDNA data on file with Better Neighbors includes VRBO and Airbnb listings within the City of Santa Ana through March 2023. https://www.airdna.co/ 250 East 1 st Street, Suite 1201; Los Angeles, California 90012 213.336.5900 0 betterneighborsla. org Better Neighbors Comment Letter Agenda Item 3 5: Repeal and Re-enact Short Term Rental Regulations Page 2 of 4 confirmed active STR enforcement cases involved properties owned by an LLC, managed by a property management company, or owned by absentee owners. Below please find the growth in short-term rentals from 2014 to 2023. AVERAGE ACTIVE SHORT-TERM RENTAL LISTINGS IN SANTA ANA ■ Unhosted Units Hosted Units 1200 1000 800 600 201 295 400 140 105 m 126 133 200 21 33 54 78 1 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 As of March 2023, the most recent data we have available, there were 991 active STR listings in Santa Ana, making up 1.27% of Santa Ana's housing stock.3 Short-term rentals have grown significantly over the last few years, and in the process have taken housing units off the long-term market that may have otherwise been available to long-term tenants or potential homeowners. According to the staff report, there are more than 700 STRs currently operating in Santa Ana. These 700 STRs account for 22% of the 3,137 permanent housing units that the City has identified as required by the 2021-2029 Regional Housing Needs Allocation (RHNA). Ensuring that the prohibition of short-term rentals remains in place in the City of Santa Ana will safeguard this milestone in meeting the 2021-2029 RHNA goals. Santa Ana is not alone in their push to ban short-term rentals. Within Orange County, at least twelve cities have taken steps to prohibit short-term rentals in some form. These cities include the Aliso Viejo, Brea, Costa Mesa, Fountain Valley, Garden Grove, Irvine, Laguna Hills, Laguna Nigel, Villa Park, Westminster, Yorba Linda, and La Habra.4 In Los Angeles County, the 3 Profile of the City of Santa Ana, Southern California Association of Governments, https://sca�ca.j4ov/sites/main/files/file- attachments/santaana_localprofile.pdV 1606012682. 4 City of Aliso Viejo: https://www.codepublishina.com/CA/AlisoViejo/html/AlisoViejol5/AlisoViejol5l4.html; City of Brea: https:Hcodelibrary.amle�,Fal.com/codes/brea/latest/brea ca/0-0-0-70791; City of Costa Mesa: https://weblink.costamesaca.gov/WebLink/DocView.aspx?id=233471&dbid=0&repo=CityofCostaMesa; City of Fountain Valley: https://www.fountainvalley..gov/DocumentCenter/View/16275/Ordinance-No-1591; City of Garden Grove: https:Hecode360.com/42535001; City of Irvine: https://library.municode.com/ca/irvine/codes/zoninl4?nodeld=ZOOR DIV3GEDESTLAUSRE_CH3-25SHTERE_S3-25- 5VIMIIN#:—:text=3%2D25%2D3..of%20short%2Dterm%20rentals%20Drohibited.&text=section%20ComDare%20versions- A.,zoninj4%20district%20within%20the%20City; City of Laguna Hills: 250 East 1 st Street, Suite 1201; Los Angeles, California 90012 213.336.5900 0 betterneighborsla. org Better Neighbors Comment Letter Agenda Item 3 5: Repeal and Re-enact Short Term Rental Regulations Page 3 of 4 City Councils of Calabasas, Diamond Bar, Rosemead, Culver City, West Hollywood, San Gabriel, La Mirada, Lakewood, Rolling Hills, Redondo, and Lawndale all have short-term rentals bans in place. 5According to a study published in the Real Estate Economics Journal in 2023, in the City of Irvine rental prices decreased 3 % on average following two years after the enforcement of their ordinance prohibiting short-term rentals in all residential zones.6 This study illustrates the positive impacts a prohibition on short-term rentals can have on addressing the affordability of housing in cities within Orange County. Given that a majority of housing units within Santa Ana are renter occupied, it is likely that a similar prohibition on short-term rentals will protect further protect tenant households. 7 A ban on short-term rentals is only as valuable as the enforcement that backs it. To see positive effects on the housing and rental market, Santa Ana should adopt the resolution to enhance administrative fines for violation of the ordinance and implement a centralized enforcement system to administer them. In Los Angeles, high administrative burden and a decentralized system of the Home -Sharing Ordinance enforcement has led to rampant abuse of the short-term rental market. For example, in July of 2024, Los Angeles has over 6,000 listings that are noncompliant with the Home -Sharing Ordinance.8 Between January and August of 2024, the City only issued 97 citations despite the high number of noncompliant listing.9 With a prohibition in place and enhanced administrative fines for violating the ordinance, Santa Ana can ensure that the City has strong, easily enforceable rules in order to issue citations and maintain the ordinance's effectiveness. https://www.codepublishing.com/CA/LagunaHills/#!/LagunaHills06/LagunaHillsO640.html , City of Laguna Nigel: https://library.municode.com/ca/laguna_niguel/codes/code_of ordinances?nodeId=TIT9PLZ0_DIVIPL_ART2COZOCO_SUB ARTICLE _3REDI S9-1-3 8GRHO; City of Villa Park: https://library.municode.com/ca/villa park/codes/code_of_ ordinance s?nodeId=CHXXIIIZO_ART23-3EFZORE_S23- 3.5SHRMRE; City of Westminster: htlps://Iibraly.qcode.us/lib/westminster_ca/pub/municipal code/item/title_9-chapter_9_74- 9_74_020; City of Yorba Linda: htlps://Iibraly.qcode.us/lib/yorba linda ca/pub/municipal_ code/item/title_5-chapter 5_50- 5_50_030. City of La Habra: https://www.lhhcily.org/325/Short-Term-Rentals 5 Calabasas: https://Iibrary.municode.com/ca/city of_calabasas/codes/code_ of ordinances?nodeId=TIT 17LAUSDE_ARTIIZODIALLAUS_C H17.12STSPLAUS 17.12.175SHRMREOCPRPREXLAAPHOMOBEBRIN; Diamond Bar: https://www.diamondbarca. og v/Faq.aspx?QID=314; Rosemead: https://library.municode.com/ca/rosemead/ordinances/code_of ordinance s?nodeId=900458; Culver City: https://www.culvercity.org/Have-Your-Say/Short-Term-Rentals; West Hollywood: https://ecode360.com/43916115?hi h�lip,Fht=rental,rentals&searchId=1904165411732459#43916115; San Gabriel: https://www. sany,fabrielcity.com/1341/Frequently-Asked-Questions#::text=Short- term%20rentals%20(anything%201ess,term%20rental%20or%; La Mirada: https://www.airbnb.com/help/article/2692#:—:text=Short%2Dterm%20rentals%20in%2Oresidential,not%20permitted%20in%20L a%20Mirada; Lakewood: https://www.lakewoodcily.org/Business/Short-term-rentals Rolling Hills: https://Iibrary.municode.com/ca/rolling hills estates/codes/code—of ordinances?nodeId=TIT17Z0_CH17.47SHRMRERE_17.47 .020PU; Redondo Beach: hgps://www.redondobeachtourism.com/news/airbnb; Lawndale: https://ecode360.com/LA4957 6 https://onlinelibrary.wiley.com/doi/abs/10.1111/1540-6229.12440 According to the City of Santa Ana General Plan Housing Element, in 2018 53.8% of households were renter occupied, while 46.1 % were owner occupied, https://docs. 0000gle.com/viewemj4/viewer?url=https://storaie. 0000gleapis.com/proudcily/santaanaca/uploads/2022/09/Housing El ement_-Complete-9.16.22_Compressed.pdf 8 Data on file with BNLA from Los Angeles City Granicus data. hgps://granicus.com/ 9 Data on file with BNLA from Los Angeles City Planning Department. 250 East 1 st Street, Suite 1201; Los Angeles, California 90012 213.336.5900 0 betterneighborsla. org Better Neighbors Comment Letter Agenda Item 3 5: Repeal and Re-enact Short Term Rental Regulations Page 4 of 4 The proposed ordinance will further codify the prohibition and continue protecting long- term residents. According to the City of Santa Ana General Plan Housing Element, almost half (48%) of all households spend more than 30% of their income on housings costs and thus are considered cost burdened. In addition, the National Low Income Housing Coalition, the fair market rent for a two -bedroom home is $2,100, meaning a household would have to earn more than $40/hour to afford to house their family.10 As residents in the City of Santa Ana continue to bear the impacts of high housing costs, it is imperative the City protect and preserve housing for long-term residents. For these reasons, Better Neighbors requests the City Council uphold the short-term rental ordinance passed in April of this year by repealing and re-enacting the Short -Term Rental Ordinance and adopting enhanced fines for violations. Should you have any questions, please contact Maura O'Neill at mauragbetterneighborsla.org. Sincerely, Better Neighbors LA & Unite HERE Local 11 10 Data for zip code 92701, https://nlihc.org/oor/zip?code=92701. 250 East 1 st Street, Suite 1201; Los Angeles, California 90012 213.336.5900 0 betterneighborsla. org Alcala, Abigail From: Gavin Williams < Sent: Tuesday, November 19, 2024 5:55 PM To: eComment Subject: I don't want short term rentals in Santa Ana. Ever! Attention: This email originated from outside of City of Santa Ana. Use caution when opening attachments or links. Sent from my iPhone