Response to Late Comments Item No.15

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translutions, inc. 17632 Irvine Boulevard, Suite 200, Tustin, California 92780 Phone (949)656-3131 Fax (949)445-3131 solutions@translutions.com November 29, 2024 File Subject: Santa Ana Ordinance Transportation Analyses Support Translutions, Inc. (Translutions) is pleased to present this memorandum evaluating potential issues with the proposed Short-Term Rental (STR) Ban in the City of Santa Ana, in Orange County, California. It is our understanding that the ordinance would affect approximately 700 - 1000 currently active units. This memorandum focuses on the potential for the STR Ban to increase Vehicle Miles Traveled (VMT) and trip generation. VEHICLE MILES TRAVELED VMT analysis is a requirement under CEQA due to the passage of Senate Bill 743 (SB-743).SB-743 was codified in Public (OPR) to identify alternative metrics for evaluating transportation impacts under CEQA. Pursuant to Section 21099, the criteria for nt This resulted in changes to the CEQA guidelines in response to Section 21099 including a new section (15064.3) that specifies that Vehicle Miles Traveled (VMT) is the most appropriate measure of transportation impacts. A separate Technical Advisory issued by OPR provides additional technical details on calculating VMT and assessing transportation impacts for various types of projects. The City adopted thresholds of significance and screening thresholds under VMT in February 2019. An increase in VMT is a reasonably foreseeable result of the STR ban for several reasons. First, the increased trips directly correlate to greater vehicle travel and VMT compared to the baseline. Second, the STR ban would likely incentivize increased VMT from individuals that seek available or more affordable hotels in neighboring or regional communities, thereby increasing VMT to/from the non-local hotel compared to VMT to/from a local hotel. Third, the STR ban would force any user that prefers STRs to hotels to travel to neighboring or regional communities because STRs are no longer allowed in the City, thereby directly causing increase in VMT traveling to/from the non-local STR compared to the baseline where STRs are available in the City. TRIP GENERATION th Trip generation is generally based on the ITE Trip Generation, 11 Edition. The ITE Trip Generation does not have rates for STRs. Therefore, the trip generation of STRs are based on rates for All Suites Hotels and using rates from Recreational Homes, which are the closet uses with published rates. It should be noted that the trip generation of All Suites Hotel is likely to be higher than was compared to those of hotels since it is likely that if STRs are disallowed, guests would potentially stay in hotels. Based on publicly available statistics on the current Airbnb listings in Santa Ana, the average capacity per STR is 5.6 people, which has been converted to equivalent hotel rooms, assuming one hotel room has a capacity of 3 people. Further, two trip generations have been calculated, one using the numbers included in the staff report (700 units) and the other based on the number of SRTs under operation in Santa Ana obtained from online data analytics (1,000 units). Applying the STR to Hotel Room conversion ratio of 1.867 (5.6 people per room/3 people per room), 700 STRs would require 1,307 replacement hotel rooms while 1,000 STRs would require 1,867 replacement hotel rooms. Table A shows the trip generation of 700 STRs using the two rates and 1,307 replacement hotel rooms, while Table B shows the trip generation of 700 STRs using the two rates and 1,867 replacement hotel rooms.