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ENVIRONMENT <br />& HEALTH <br />MEMO <br />To File <br />From Eric C. Lu, Sarah Manzano, and Brent Ferren <br />Subject ENVIRONMENTAL ANALYSIS OF SHORT-TERM RENTAL <br />REGULATION <br />Ramboll Americas Engineering Solutions, Inc. (Ramboll) evaluated potential air <br />Date: November 14, 2024 <br />quality, greenhouse gas (GHG), energy and noise environmental impacts of a <br />potential ban on short-term rentals (STR) in Santa Ana, California. As discussed <br />throughout this memo, Ramboll found that the ban of STRs in Santa Ana has the <br />potential to increase emissions and noise that should be evaluated further. The <br />increase in emissions and noise have the potential to cause a significant impact in <br />relation to California Environmental Quality Act (CEQA). Ramboll's analysis was <br />informed by the economic analysis performed by Ramboll's Stefanie O'Gorman <br />Ramboll <br />(see Exhibit A) . <br />250 Montgomery St., <br />Suite 1200 San Francisco, <br />CA 94104 US <br />1 Overview <br />USA <br />T+ 1 510 655 7400 <br />As a result of the proposed STR ban, individuals would be unable to enjoy the F+1 510 655 9517 <br />benefits of STRs within Santa Ana, which will increase demand for local hotels as https://ramboll.com <br />the only option for short term stays within Santa Ana. As a result, individuals will <br />be forced to travel greater distances to other commercials centers in the region <br />to find available STRs and available/affordable hotels, introducing additional <br />vehicle miles traveled (VMT). In particular, increased travel to and from hotels <br />and STRs in the region because of the unavailability of STR in Santa Ana could <br />increase emissions relative to South Coast Air Quality Management District <br />(SCAQMD) thresholds for criteria air pollutants (CAPs), with the potential to cause <br />short-term and long-term health impacts to sensitive receptors, exceedances of <br />appliable air quality standards, and inconsistencies with applicable air quality and <br />climate plans, all of which create a fair argument of environmental impacts that <br />need to be studied further under CEQA. The ban of STRs will also likely result in <br />increased traffic congestion and noise impacts that require further study under <br />CEQA.1, 2 <br />1 Airbtics reports approximately 1,000 short-term rentals in Santa Ana, which is <br />referenced throughout this analysis. However, conclusions herein are largely based on <br />comparative impacts to the elimination of short-term rentals and are not dependent on <br />the actual number of short term rentals in Santa Ana today. <br />2 https://app.airbtics.com/airbnb-data/united-states/CA/santa%20ana <br />1/14 <br />