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5820 Canoga Avenue, Suite 300 <br />Woodland Hills, CA 91367 <br />T (818) 933-0200 <br />F (818) 933-0222 <br />www.gaineslaw.com <br />November 18, 2024 <br />VIA EMAIL eCommenWsanta-ana.or <br />Mayor Valerie Amezcua <br />Mayor Pro Tem Thai Viet Phan <br />Councilmember Benjamin Vazquez <br />Councilmember Jessie Lopez <br />Councilmember Phil B acerra <br />Councilmember Johnathan Ryan Hernandez <br />Councilmember David Penaloza <br />Santa Ana City Council <br />City Council Chamber <br />20 Civic Center Plaza M-30 <br />Santa Ana, CA 92701 <br />Re: November 19, 20241 City Council Meeting — Item 35: Ordinance Amendment No. 2024- <br />04 Repealing and Reenacting in its Entirety Article XXI to Chapter 8 of the Santa Ana <br />Municipal Code Prohibiting Short -Term Rentals, and Adopt Enhanced Fines for <br />Violations of the Short -Term Rentals Ordinance <br />Dear Mayor Amezcua and Honorable City Councilmembers, <br />This law office represents the Santa Ana Short -Term Rental Alliance ("Rental Alliance"), whose <br />members own and operate STRs within the City. Thank you for the opportunity to submit these <br />comments on behalf of the Rental Alliance on the City's proposed Ordinance Amendment No. <br />2024-04, amending the Santa Ana Municipal Code ("SAMC") to repeal and reenact a prohibition <br />on short-term rentals ("STRs") (the "Amended Ordinance"). <br />As we detail below, consistent with many of our prior comments, the City's proposed prohibition <br />of STRs would (a) result in significant environmental impacts, (b) violate state and federal law, <br />and (c) unconstitutionally infringe on the rights of hosts and their guests. We also present new <br />evidence by technical experts demonstrating the STR ban will adversely impact the physical <br />environment by causing reasonably foreseeable increases in vehicle miles traveled ("VMT"), air <br />pollutants (and related adverse health consequences), greenhouse gas emissions, and fossil fuel <br />consumption. As just one example from the attached technical reports: when comparing visitors <br />staying at a hotel compared to an STR, mobile emissions of volatile organic compounds, nitrogen <br />oxides ("NOx"), and micro particulates ("PM 2.5") all scientifically proven to contribute to smog <br />and increase risks of cancer, asthma, lung damage, and other health impairments were calculated <br />