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396 HAYES STREET, SAN FRANCISCO, CA 94102 <br />T: (415) 552-7272 F: (415) 552-5816 <br />www.smwlaw.com <br />December 7, 2021 <br />Via Electronic Mail Only <br />Santa Ana City Council <br />c/o Daisy Gomez <br />Clerk of the Council <br />20 Civic Center Plaza M-30 <br />Santa Ana, CA 92701 <br />ecomment@santa-ana. org <br />Re: Santa Ana General Plan Update <br />Dear Mayor Sarmiento and Council Members: <br />KATRINA A. TOMAS <br />Attorney <br />ktomas@smwlaw.com <br />On behalf of Orange County Environmental Justice ("OCEJ"), I write to <br />provide comments on the Santa Ana General Plan Update and its accompanying Final <br />Recirculated Program Environmental Impact Report ("FEIR" ). Shute, Mihaly & <br />Weinberger, LLP previously submitted comments on behalf of OCEJ on the Recirculated <br />Draft Program Environmental Impact Report ("RDPEIR') in a September 20, 2021 letter <br />to the Planning Commission. Unfortunately, the City has not adequately addressed the <br />various issues noted in these previous comments. As a result, the General Plan Update as <br />written and its accompanying FEIR remain flawed. <br />L The City Failed to Investigate Environmental Justice Concerns. <br />At the heart of the issues plaguing the General Plan Update and its FEIR, is <br />the City's rushed approval process that has continuously neglected community concerns <br />and input. The California Environmental Quality Act ("CEQA"), Public Resources Code <br />section 2100 et seq.,1 requires a thorough evaluation of the General Plan Update's <br />environmental impacts. This includes impacts to environmental justice communities as a <br />result of soil lead contamination. The FEIR's meagre attempts at an investigation through <br />the environmental justice community engagement survey ("community survey") fails to <br />1 Undesignated statutory references are to the Public Resources Code. References to the <br />"CEQA Guidelines" are to title 14, Cal. Code of Regulations, section 15000 et seq. <br />