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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 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