Response to Comments - Agenda Item No. 35

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ÐP visitors traveling to and from various STRs located throughout the City would result in more diversified traffic patterns as all visitors are not driving to one area. Furthermore, a potential new hotel constructed to meet the demand as a result of the STRs ban would likely be constructed in the area of Santa Ana with the majority of hotels, further concentrating traffic in this area. Health Risk Impacts from Traffic Ramboll performed a preliminary analysis that quantified the health risks from traffic emissions in order to assess the impact that increased hotel use in Santa Ana due to a ban on STRs could cause. A typical roadway with approximately 30,000 average annual daily trips (AADT) results in an excess cancer risk 11,12,13 of 40 in a million at a nearby residential receptor. According to ITE, hotels generate 7.99 trips per 14 day per hotel room. There are currently approximately 1,000 Airbnbs in Santa Ana, with other STRs 15 also available. Assuming this ban contributes to 950 more hotel rooms being used, traffic would increase by 7,560 vehicles per day, which results in health impacts that would exceed 10 in a million, which is the SCAQMD CEQA threshold of significance for cancer risk. This scaling approach also does not take into account increased truck traffic associated with deliveries to a hotel that would not occur to an STR. Therefore, banning STRs in Santa Ana could result in an increase in traffic on certain roadways that could be considered significant. If additional truck trips were taken into account, the number of hotel rooms that could cause an exceedance of the threshold of significance for cancer risk could be lower than 950 hotel rooms. It could be assumed that similar trends to cancer risk based on near-roadway traffic exposure would be true for particulate matter and toxic air contaminant emissions. Noise Impacts from Traffic Ramboll evaluated whether a potential traffic volume increase could cause a traffic noise increase that is considered either substantial (per CEQA guidelines) or increases the ambient conditions to a level above the Santa Ana General Plan Noise Element standard (65 dBA CNEL). Traffic noise analyses require specific knowledge of existing and future traffic volumes and vehicle mixes as well as project-related traffic volumes and mixes. In this case, this information is currently unknown. However, the following figure shows the current (2022) exterior levels of noise created by cars, trucks, or trains traveling along roadways and rail lines in the City. The CityÓs noise and land use compatibility standards (see Table N-1) consider exterior levels above 65 dBA (CNEL) to be generally incompatible for residential and other noise-sensitive land uses. If residential or other noise-sensitive areas within the City that are currently below the 65 dBA CNEL level experienced traffic volume increases, specifically due to an increased hotel demand resulting from 11 Health impacts obtained from highway 152 from the Bay Area Air Quality Management District (BAAQMD) Mobile Source Screening tool at a distance of 100 feet from the roadway. This was used as a surrogate to estimate general health risks from only traffic. The traffic volume along this road was obtained from CalTrans. 12 Bay Area Air Quality Management District (BAAQMD). 2022. CEQA Roadway Screening Tool - Cancer Risk. Available at: https://data.bayareametro.gov/Environment/CEQA-Roadway-Screening-Tool-Cancer-Risk/kz4a-ueki 13 CalTrans, Traffic Census Program. Available at: https://dot.ca.gov/programs/traffic-operations/census. 14 ITE. Trip Generation Manual 11th Edition. 15 https://app.airbtics.com/airbnb-data/united-states/CA/santa%20ana?payment-plan=pro&payment- duration=yearly 9/14