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Community Development Depaiti.i.ient TUSTIN December 7, 20211 Mayor Sarmiento and (Members of the City Council City of Santa Ana 20 Civic Center Plaza Santa Ana, CA 92702 ecomments ments@santa-aiia.org HISTORY BUILDING OUR FUTURE HONORING OUR PAST Re: Santa Ana General Plan Update and Program Environmental Impact Report (State Clearinghouse Dumber: 2020029087) Mayor Sarmiento and Members of the City Council: The City of Tustin appreciates the opportunity to submit this letter on the Santa Ana. General Flan Update (GPU) and its Final Program Environmental Impact Report (FEIR). As a neighboring jurisdiction, Tustin has been closely monitoring the proposed GPU as its land use changes have the potential to adversely affect the City, its residents, and its environment. Given the magnitude of development contemplated by the GPU, it is imperative that the EIR comprehensively evaluate and mitigate the GPU's environmental impacts. Unfortunately, a detailed review of the FEIR, including the responses to Tustin's September 16, 2020, October 6, 20,20 and September 20, 2021 letters, reveals that the FEIR fails to comply with the California Environmental Quality Act (CEGA). Tustin's petters identified numerous legal inadequacies in the DEIR and the Recirculated DEIR (hereinafter collectively referred to as "DEIR"). In particular, we explained that the DEIR failed to adequately analyze or mitigate the CPU's recreation, transportation, air quality, noise, and hazards impacts. We also determined that the DEIR failed to provide a legally defensible alternatives analysis, Such fundamental errors undermined the integrity of the DEIR, The FEIR dismisses many of Tustin's comments and downplays numerous others. In many instances, the IFEIR merely seeks to defend the erroneous assertions and conclusions of the prior documents. The remainder of this letter addresses the FEIR's legal deficiencies. We will not reiterate the comments raised in our prior letters to Santa Ana. Instead, we will elaborate on some of the FEIR's most serious shortcomings.. The FEIR Fails to Rectify Deficiencies in the EIR's Analysis of and (Mitigation for Park and Recreation Impacts. As we explained in our prior petters, the DEIR erred because it did not analyze park and recreation impacts to the City of Tustin that would result from the GPU's proposed development. We explained that-these impacts are likely to be acute given the deficient supply of parkland in Santa Ana and the lack of existing parks in the 55 Freeway/Dyer Road focus area in particular. The FEIR does nothing to resolve this legal deficiency as it fails to make any attempt to analyze the GPU's impacts to Tustin's 300Centennial Way, T-ustin, CA g 78o 0 P: (714) 573-3100 @ F: (714) 573-3113 a wwwAnstir1ca.org