Response to Comments - Agenda Item No. 35

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ÐP 4 An STR Ban Will Disproportionally Burden Environmental Justice Communities The proposed STR ban in Santa Ana, CA, raises critical environmental justice concerns, particularly given the CityÓs existing pollution burdens from regional pollution and localized traffic exposure near the existing hotel stock, and the potential for increased hotel usage in response to restrictions on STRs. The existing hotels are predominately located near the I-5 and 55 freeways on the southeastern boundary of the City. This area shows elevated burden according to the California Office of Environmental Health 5 Hazard Assessment (OEHHA) CalEnviroScreen (CalEnviroScreen 4.0) data. CalEnviroScreen was developed as a mapping tool that identifies California communities most impacted by pollution and other environmental risks to identify vulnerability to adverse health effects from those sources. CalEnviroScreen takes into account environmental and socioeconomic factors to develop a percentile of burden across the State of California. Factors include indicators of pollution burden (including ozone, traffic, pesticides, drinking water) and population characteristics (including asthma, cardiovascular disease, education, poverty), which are each scored and weighted to derive a pollution burden score, population characteristic score, and the final CalEnviroScreen score. The Santa Ana tracts that border the I-5 and 55 freeways near the Southeastern boundaries of the city are identified as vulnerable tracts are also the current locations for the greatest density of hotels in Santa Ana. As shown in Figure 1, the CalEnviroScreen tool identifies Santa Ana, and particularly the freeway- th adjacent tracts, as highly burdened, being classified into the 80 percentile and above for the thrd CalEnviroScreen overall percentile, with tracts above the 90 percentile (Tract 6059074406 93 percentile as the maximum). This significant elevation in burden is driven by the pollution and exposure th burden; these freeway-adjacent tracts are ranked in the 90 percentile and above for pollution burden th (Tract 6059074003 99 percentile for pollution burden) and face extreme burden from air pollution th associated with vehicle traffic emissions, and direct traffic exposure (Tract 6059074406 99 percentile for traffic). Conversely, while central Santa Ana tracts still register as overburdened and pollution-impacted, tracts th in the center of the City are comparatively lower burdened and near the 70 percentile for overall burden. Further screening tools, the Council on Environmental QualityÓs Climate and Economic Justice Screening 6 Tool (CEJST), the US EPAÓs Environmental Justice Screening and Mapping Tool (EJScreen, Version 78 2.3), and the Public Health Alliance of Southern CaliforniaÓs California Health Places Index (HPI 3.0), each highlight significant environmental and health concerns for Santa Ana in almost all tracts, with traffic proximity and the associated vehicle traffic-generated air pollution as the driving metrics of those disadvantage and burden ratings. 5 OEHHA. CalEnviroScreen 4.0. May 2023. Available at: https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. 6 Council on Environmental Quality. Climate and Economic Justice Screening Tool. Available at: https://screeningtool.geoplatform.gov/en/. 7 US EPA. Environmental Justice Screening and Mapping Tool. Available at: https://www.epa.gov/ejscreen. 8 Public Health Alliance of Southern California. Healthy Places Index (HPI) 3.0. 2022. Available at: https://www.healthyplacesindex.org/. 5/14