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Santa Ana City Council <br />December 7, 2021 <br />Page 2 <br />meet CEQA's standards. <br />Throughout the environmental review process the City has received <br />numerous comments from OCEJ and other community stakeholders decrying the lack of <br />focused environmental assessment in disadvantaged communities despite the evidence of <br />pollutant concentrations, including lead -contaminated soils, in those communities. <br />Moreover, across several roundtable discussions, OCEJ repeatedly expressed concern <br />about the draft community survey's inadequate design. OCEJ observed that most of the <br />lead contamination -related questions assumed that the main source of lead contamination <br />was lead -based paint and neglected other sources, such as historical emissions from <br />combustion of leaded gasoline. This mischaracterized sources of lead contamination in <br />Santa Ana. Furthermore, the survey's design forced residents to choose between <br />environmental justice priorities, rather than allowing residents to highlight all of the <br />issues concerning their communities. None of these issues were rectified in the final <br />version of the survey. <br />The community survey also failed to ensure adequate participation. Out of <br />Santa Ana's 332,318 residents, only 746 completed the survey. RDPEIR at 2-23. This <br />amounts to merely 0.2 percent of the total population. Clearly, the City's outreach <br />methods were flawed. Indeed, by the City's own accounts, only 12 percent of residents <br />received a flyer encouraging participation in the community survey. See RDPEIR at 2-23. <br />Additional volunteer efforts distributed just 1,400 hard copy surveys. Accordingly, the <br />community survey cannot constitute an accurate assessment of the City's environmental <br />justice needs. <br />In the FEIR's response to comments, the City entirely fails to address these <br />issues. In fact, the City neither provides any explanation for its poorly designed <br />community survey nor addresses its ineffective community outreach. As a result, the City <br />threatens to violate CEQA. <br />The CEQA Guidelines acknowledge that "an agency must use its best <br />efforts to find out and disclose all that it reasonably can." Guidelines § 15144. The <br />Guidelines also require agencies to engage in a "thorough investigation" of a particular <br />impact. Guidelines § 15145. To fulfill CEQA's informational purpose, an agency must <br />make "a good faith effort at full disclosure." Guidelines § 15151. In particular, the City <br />"should not be allowed to hide behind its own failure to gather relevant data." Sundstrom <br />v. County of Mendocino (1988) 202 Cal.App.3d 296, 311. The community survey, which <br />captures merely 0.2 percent of the City's total population, does not meet CEQA's <br />disclosure and investigation requirements. A more thorough community engagement <br />process is needed to better inform the update to the City's General Plan. <br />1-1UIL)WIdAVY <br />�v`X/L NP)ERG1__'R , <br />