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1 30. STRs have further helped make housing affordable for those who are able to"house 2 hack"and earn money by renting portions of their houses, or the entire house, for a period of time. 3 They have made homeownership possible for many who otherwise could not afford the high cost 4 of housing and would be pushed out of the market. 5 STRs Have Long Legally Operated in Santa Ana 6 31. STRs have operated legally in the City for decades. The City acknowledged the 7 operation of STRs within its boundaries for years. For instance, on September 15, 2015, the City 8 Council implemented "an emergency ordinance adopting a 45-day temporary moratorium on the 9 establishment or expansion of any short term residential rental use." Ordinance No. NS-2886. 10 This ordinance acknowledged that "[t]he current provisions of the Santa Ana Municipal Code [] 11 do not clearly identify short-term residential rental uses or take into account the potential impacts 12 associated with the establishment of STRs within existing residential zones. As such, provisions 13 of . . . the Code . . . require review, study, and possible revision in order to respond to recent 14 concerns relating to the impacts of these short-term rental uses in the City." Id., Section LB 15 (emphasis added). Importantly, the emergency ordinance specially provided: "No short-term 16 residential rental is permitted in a residential zone as defined in Article I of Chapter 41 of the 17 Code." Id., Section 2. This new prohibition would not have been necessary had STRs not been 18 an existing lawful use in the City. 19 32. On October 20, 2015, the City Council considered a recommendation to extend the 20 moratorium adopted on September 15, 2015, but it declined to do so. 21 33. On information and belief, the review and study contemplated in the adoption of 22 the September 15, 2015, emergency ordinance never materialized. And, following expiration of 23 the emergency ordinance in 2015 the City issued ministerial business licenses for STRs including 24 specifically to many of the Rental Alliance's members. 25 34. In December 2021, the City adopted an ordinance that specifically regulated STRs 26 on a very small category of properties in the City referred to as "urban lot splits." Specifically, 27 Ordinance No. NS-3013 amended the Municipal Code to include the following language: "No 28 short-term vacation rentals (STRs). No dwelling unit on a lot that is created by an urban lot split VERTFTED PETTTTON FOR WRTT OF MANDATE 9 AND COMPLATNT