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would result in an increased trip length, as potential guests would have fewer options to stay as close as possible to daily destinations during their stay in Santa Ana. In addition, the number of trips taken by guests to and from their site of accommodation would be higher for hotels than for short-term rentals, as evidenced by Institute of Transportation Engineers (ITE), introducing additional vehicle miles traveled. Recreational Homes (ITE Land Use Code 260) have an average weekday trip generation rate of 3.55 trips per day while the Hotel land use (ITE Land Use 310) has 7.99 trips per day. This increase in trips may be due to the need to leave the hotel for amenities, such as food, and increased worker trips. The increase in mobile emissions associated with short-term rentals compared to hotels is presented below in Table 1. Based on publicly available statistics on the current Airbnb listings in Santa Ana, the average capacity per STR is 5.6 people and there are approximately 1,000 active Airbnb listings.3 This results in a service population of 5,600 people. As a result of the potential STR ban, this would require 1,867 hotel rooms to accommodate this same service population assuming one hotel room has a capacity of 3 people. The number of peak daily trips was estimated using the ITE trip rates for STRs and hotel rooms and the number of STRs and hotel rooms required to serve the same population. The number of daily miles traveled was estimated assuming a single trip to a hotel is 2 miles longer than a single trip to a STR since guests might have to stay farther from daily destinations if they stay at a hotel. These assumptions were used to determine daily mobile emissions. Mobile emissions from visitors staying at a hotel would generate up to 444 percent more criteria air pollutant emissions and GHGs than from visitors staying at an STR.4 Therefore, the ban has the potential to considerably increase emissions in the area. The increase in VMT and greenhouse gas emissions is directly inconsistent with regional and state goals to reduce VMT and greenhouse gas emissions from vehicle trips. Additional calculation details can be found in Appendix A. Table 1. Emissions Increase due to Additional VMT Percent Increase in daily mobile Criteria Air Pollutant emissions from STR to hotel to serve the same population VOC 442% N Ox 443% CO 443% Sox 444% PM10 444% P M i.s 444% GHG (COZe) 443% 3 https://app.airbtics.com/airbnb-data/united-states/CA/santa%20ana 4 This percent increase is independent of the number of short-term rentals in Santa Ana. The number of short-term rentals and population are provided for illustrative purposes only. 4/14