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Orozco, Norma <br /> From: Patricia Flores <patricia@ocej.org> <br /> Sent: Monday, December 06, 2021 6:23 PM <br /> To: eComment <br /> Subject: Public Comment: Do Not Approve the Santa Ana General Plan Update <br /> Dear Santa Ana City Council: <br /> We are writing to you as iPlo-NO! Santa Ana, a collaborative including Orange County Environmental Justice (OCEJ), <br /> Jovenes Cultivando Cambio (Youth Cultivating Change), and researchers from the UC Irvine Program in Public Health <br /> and the UCI Community Resilience Project, which formed in 2017 to investigate soil-lead contamination and advocate for <br /> remediation and the health equity needs of Santa Ana's disadvantaged communities. We are a coalition of grassroots <br /> leaders, Santa Ana residents, and community-driven scholars with backgrounds in public health, history, environmental <br /> sciences and law, and we are writing to ask that you vote to not approve the Santa Ana General Plan Update <br /> (GPU), until it includes policies to comprehensively address the decades-long soil-lead crisis and its toll on the <br /> health of our most vulnerable communities.We are concerned that the community outreach process for the GPU has <br /> not sufficiently engaged with the perspectives and needs of impacted residents, and that the current policies do not <br /> adequately remediate the environmental injustices faced by our city's most vulnerable communities. <br /> From 2018 to 2019, our collaborative collected 1555 soil samples from across Santa Ana, tested them for soil-lead <br /> content, and found that 52.7% of residential samples had Pb concentrations in excess of the 80 ppm safety threshold <br /> established by the California EPA's Office of Environmental Health Hazard Assessment, and 11 Census tracts were <br /> characterized as high risk according to our Cumulative Risk Index. What's more, we found that the neighborhoods most <br /> impacted by soil-lead contamination were also: <br /> • Predominantly people of color <br /> • Lower median household income <br /> • Lower% of college educated residents <br /> • Higher proportions of renters <br /> • Higher fraction of residents without health insurance <br /> • Higher proportion of residents with immigrant status background <br /> • Limited English proficiency <br /> • Predominantly Latinx/Hispanic residents <br /> The State of California defines Environmental Justice (EJ) in section 65040.12(e)of California Government Code as "the <br /> fair treatment and meaningful involvement of people of all races, cultures, incomes, and national origins with respect to <br /> the development, adoption, implementation, and enforcement of environmental laws, regulations, and policies." By this <br /> definition, Santa Ana's low-income residents of color are suffering a great environmental injustice, and the General Plan is <br /> our city government's opportunity to implement comprehensive policies to address this injustice. <br /> When Santa Ana residents mobilized last Fall to ask that the city undergo an outreach and engagement process to <br /> include the needs and voices of our most impacted community members, we were pleased that the city paused adoption <br /> of the General Plan Update and invited our collaborative, among other important stakeholders, to a series of roundtable <br /> discussions to inform the development of a community survey. We provided feedback that the survey's design forced <br /> residents to choose between environmental justice priorities, rather than allowing them to highlight all of the issues that <br /> affect their communities. Furthermore, we observed that most of the lead contamination-related questions assumed that <br /> the main source of lead contamination was lead-based paint and neglected other sources, such as historical emissions of <br /> leaded gasoline, which, according to the literature, was the largest contributor of lead to urban environments. They also <br /> relied on residents having specific data about the sources of lead contamination in their properties and neighborhoods, <br /> including information such as the year in which their home was built, which is not common knowledge for most renters. <br /> We were disappointed, however, to see that the city did not address these concerns in the final version of the survey <br /> disseminated to Santa Ana residents and, although soil-lead contamination still emerged as the second highest priority, <br /> we believe that a better-structured survey would have more accurately represented the perspectives of our communities. <br /> 1 <br />