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Response to Comments - Agenda Item No. 35
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Response to Comments - Agenda Item No. 35
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City Clerk
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35
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11/19/2024
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ÐP <br />would result in an increased trip length, as potential guests would have fewer options to stay as close as <br />possible to daily destinations during their stay in Santa Ana. <br />In addition, the number of trips taken by guests to and from their site of accommodation would be <br />higher for hotels than for short-term rentals, as evidenced by Institute of Transportation Engineers <br />(ITE), introducing additional vehicle miles traveled. Recreational Homes (ITE Land Use Code 260) have <br />an average weekday trip generation rate of 3.55 trips per day while the Hotel land use (ITE Land Use <br />310) has 7.99 trips per day. This increase in trips may be due to the need to leave the hotel for <br />amenities, such as food, and increased worker trips. <br />The increase in mobile emissions associated with short-term rentals compared to hotels is presented <br />below in Table 1. Based on publicly available statistics on the current Airbnb listings in Santa Ana, the <br />3 <br />average capacity per STR is 5.6 people and there are approximately 1,000 active Airbnb listings. This <br />results in a service population of 5,600 people. As a result of the potential STR ban, this would require <br />1,867 hotel rooms to accommodate this same service population assuming one hotel room has a <br />capacity of 3 people. The number of peak daily trips was estimated using the ITE trip rates for STRs and <br />hotel rooms and the number of STRs and hotel rooms required to serve the same population. The <br />number of daily miles traveled was estimated assuming a single trip to a hotel is 2 miles longer than a <br />single trip to a STR since guests might have to stay farther from daily destinations if they stay at a <br />hotel. These assumptions were used to determine daily mobile emissions. <br />Mobile emissions from visitors staying at a hotel would generate up to 444 percent more criteria air <br />4 <br />pollutant emissions and GHGs than from visitors staying at an STR. Therefore, the ban has the <br />potential to considerably increase emissions in the area. The increase in VMT and greenhouse gas <br />emissions is directly inconsistent with regional and state goals to reduce VMT and greenhouse gas <br />emissions from vehicle trips. <br />Additional calculation details can be found in Appendix A. <br />Table 1. Emissions Increase due to Additional VMT <br />Percent Increase in daily mobile <br />Criteria Air Pollutant emissions from STR to hotel to serve <br />the same population <br />VOC 442% <br />NO 443% <br />x <br />CO 443% <br />SO 444% <br />x <br />PM 444% <br />10 <br />PM 444% <br />2.5 <br />GHG (COe) 443% <br />2 <br /> <br />3 <br /> https://app.airbtics.com/airbnb-data/united-states/CA/santa%20ana <br />4 <br /> This percent increase is independent of the number of short-term rentals in Santa Ana. The number of short-term <br />rentals and population are provided for illustrative purposes only. <br /> <br />4/14 <br /> <br /> <br />
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