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