Item No. 1_Public Comment_Willowick

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Verny Carvajal October 6, 2020 Page 7 issues will be incorporated throughout the Update. DPEIR at 3-17. The Update includes several draft goals and policies which refer to equity and environmental justice (See DPEIR at B-a-2, B-a-5, B-a-19, B-a-20, B-a-25, B-a-39, B-a-41, B-a-43, B-a-44). Despite the Update’s inclusion of these policies, the DPEIR makes no attempt to analyze the Update’s environmental justice impacts on disadvantaged communities. CEQA requires an evaluation of the Update’s significant environmental effects and consistency with applicable General Plan policies. 14 Cal. Code Regs §§15126.2(a), 15125(d). The Update includes goals and policies that seek to promote environmental justice by addressing air pollution, hazardous waste exposure, and other impacts on disadvantaged communities. See, e.g., DPEIR at B-a-25 (Policy CN-1.5; air pollution and environmental justice), B-a-39 (Policy S-2.6; hazardous materials and environmental justice), B-a-43 (Policy LU-3.9; polluting land uses and environmental justice). The DPEIR should consider whether other aspects of the Update would have significant environmental impacts on disadvantaged communities,2 and whether those elements would impede the Update’s environmental justice goals and policies, creating an internal inconsistency within the General Plan. See Gov. Code § 65300.5 (requiring “internally consistent” General Plan); Sierra Club v. Kern County Board of Supervisors (1981) 126 Cal.App.3d 698, 704. The DPEIR should comprehensively analyze environmental justice impacts, including air quality and pollution exposure in disadvantaged communities as well as access to public facilities such as parks and access to healthy food. As part of its environmental justice analysis, the DPEIR should consider whether the Update may result in conflicts between industrial or commercial uses and proposed housing in corridors that the Update has designated for upzoning. It should particularly analyze any resulting impacts on disadvantaged communities. For example, air pollutant emissions from light industrial uses may affect air quality in the areas designated for increased residential density, potentially increasing residents’ exposure to air pollution. Notably, four of the five “focus areas” designated for residential upzoning under the Update also include land designated for industrial uses. DPEIR at 1-6. This would potentially cause an disproportionate adverse impact on disadvantaged communities. Moreover, the effect of the Update policies promoting such development would cause harms contrary to Update policies on environmental justice- an internal inconsistency. 2 The CEQA guidelines make clear that “economic and social effects of a physical change may be used to determine that the physical change is a significant effect on the environment” and that “[i]f the physical change causes adverse economic or social effects on people, those adverse effects may be used as a factor in determining whether the physical change is significant.” 14 Cal. Code Regs. § 15064(e); see also id. §15382.