Item 37 - EIR No. 2020-03 and GPA No.2020-06 Santa Ana General Plan Update

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Community Development Depaiti.i.ient Mayor Sarmiento and Members of the City Council City of Santa Ana 20 Civic Center Plaza Santa Ana, CA 92702 ecomments@santa-aiia.org 1111111 Fill .1 0, I -All L�,111011.6 NIM-1 ................ TUSTtN BUILDING OUR FUTURE HONORING OUR PAST The City of Tustin appreciates the opportunity to submit this letter on the Santa Ana General Plan 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 (CEQA). Tustin's letters 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 andl 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 DE�IRs Analysis of and Mitigation for Park and Recreation Impacts. As we explained in our prior letters, the DEIR erred because it did not analyze park and recreation impacts to the City of Tustin that would result from the GIPU's proposed development. We explained that -these impacts are likely to be acute given the deficient supply of parkl'and in Santa Ana and the lack of existing parks in the 55 Freeway/Dyer Road focus area in particular. The FEIR does nothing to-cec—1 . %/a ar - - - Ii. I 'J "1 11 1 i2LLI� I n Ti icti 300 Centennial Way, T-ustin, CA 9278o 0 P: (714) 573-3100, @ F: (714) 573-3113 a wvTwAusfir1ca.org