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Correspondence - PH #35
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Correspondence - PH #35
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35
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11/19/2024
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M B dLL <br />Table 4. Noise Impact from Traffic Increase <br />Traffic Volume Increase <br />Potential Traffic Noise Increase <br />25% <br />1 dB <br />50% <br />2 dB <br />100% <br />3 d B <br />8 Elimination of Short -Term Rentals Could Cause the Construction of New Hotels <br />to Meet Demand; the Construction of New Hotels Would Result in Numerous <br />Environmental Impacts That Require Studying <br />As detailed in the Ramboll memorandum ""ECONOMICS ANALYSIS OF SHORT-TERM RENTAL <br />REGULATION", the prohibition of STRs, including those currently operating within the City, could compel <br />tourists to seek alternative accommodations, increasing demand for hotels and potentially leading to the <br />development of additional hotels as a reasonably foreseeable consequence of the STR ban. The <br />construction of hotels has impacts on the environment that have not been studied. In particular, <br />construction of hotels has potential noise and air quality impacts as discussed below. <br />Potential Hotel Construction Air Quality and Health Impacts Resulting from STR Ban <br />Ramboll performed a screening health risk assessment to determine the potential cancer risk resulting <br />from construction activity of a hypothetical new hotel. The emissions associated with the construction of <br />these hotels encompass on -site, off -road heavy equipment, off -site, on -road vehicle travel, architectural <br />coating, paving, and fugitive dust. Ramboll utilized CalEEMod to estimate construction emissions from a <br />250-room hotel as shown in Appendix B, which is an average mid -size hotel. <br />Ramboll used an existing hotel project site to model emissions in AERMOD as a surrogate for the space <br />of hotel construction. Concentrations resulting from diesel particulate matter (DPM) emissions from off - <br />road construction equipment in CalEEMod were modeled on receptors in a grid of 20 meters. The health <br />risk assessment used default exposure assumptions for residents as outlined by OEHHA.16 <br />As indicated in Table 5, the construction of a hotel without emissions mitigation results in an excess <br />cancer risk of 48 in a million for the maximum exposed individual (MEI), which exceeds the SCAQMD's <br />threshold of 10 in a million. Cancer risks continue to exceed the threshold until a distance of 450 feet <br />from the construction area. <br />Table 5. Cancer Risk from Hotel Construction <br />Source <br />Cancer Risk (in a million) <br />Construction of a 250 room Hotel <br />48 <br />SCAQMD Threshold of Significance <br />10 <br />Potential Hotel Construction Noise Impacts Resulting from STR Ban <br />Construction of structures generates noise, which is regulated by the City of Santa Ana. <br />16 OEHHA. 2015. Air Toxics Hot Spots Program. Risk Assessment Guidelines. Guidance Manual for Preparation of <br />Health Risk Assessments. February. <br />11/14 <br />
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