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396 HAYES STREET, SAN FRANCISCO, CA 94102 KATRINA A.TOMAS <br /> T: (415) 552-7272 F: (415) 552-5816 Attorney <br /> www.smwlaw.com ktomas@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 /> 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 />