Item No. 1_Public Comment_Willowick

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Verny Carvajal October 6, 2020 Page 6 65300.5 (requiring “internally consistent” General Plan); Sierra Club v. Kern County Board of Supervisors (1981) 126 Cal.App.3d 698, 704. Such revisions could provide that the HOO continues to apply to projects above the pre-Update density, even if that density is allowed by right under the Update. Alternatively, the City could increase the ordinance’s inclusionary requirements, so that sufficient affordable housing is built even if the HOO applies to fewer projects. The Update’s upzoning and its obstruction of the HOO will combine to displace present community members. Much of the housing development in the upzoned areas is likely to consist of market-rate housing unaffordable to lower-income residents. This is likely to increase prices of existing lower-cost housing in the surrounding neighborhoods. Rising rents and costs of living will displace people, potentially necessitating housing construction elsewhere. As the DPEIR acknowledges, such construction is potentially a significant environmental impact under CEQA. DPEIR at 5.13-10; 14 Cal. Code Regs. Appendix G, § XIV(b). The DPEIR, however, reasons that the proposed Update “would provide more housing opportunities than currently exist” and concludes that “implementation of the [Update] would not displace people and/or housing,” leading to “no impact.” DPEIR at 5.13-14 (Impact 5.13-2). This analysis fails to take any account of the mismatch between the affordability of housing under the Update and the means of the City’s present residents. The DPEIR must reconsider its analysis of these impacts in light of the Update’s failure to provide sufficient affordable housing. III. The DPEIR does not sufficiently analyze the Update’s environmental justice impacts. The DPEIR also fails to adequately consider the Update’s environmental justice impacts. S.B. 1000 requires local governments to include an environmental justice element in their general plan (or integrate environmental justice goals and policies into other elements). Gov. Code § 65302(h). This discussion must identify “disadvantaged communities” in the jurisdiction and identify ways to reduce health risks and other impacts on those communities, as well as improvements and programs that address their needs. Id. Government Code section 65302(h)(1)(A) requires general plans to “[i]dentify objectives and policies to reduce the unique or compounded health risks in disadvantaged communities by means that include, but are not limited to, the reduction of pollution exposure, including the improvement of air quality, and the promotion of public facilities, food access, safe and sanitary homes, and physical activity.” The Update does not include a stand-alone environmental justice element, instead asserting that environmental justice