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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