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Orozco, Norma <br />From: Patricia Flores <patricia@ocej.org> <br />Sent: Tuesday, February 15, 2022 3:56 PM <br />To: eComment <br />Subject: Re: Item 26, Santa Ana General Plan Update and Environmental Impact Report <br />Dear Santa Ana City Council: <br />I am writing to urge you to not pass the Environmental Justice provisions of the General Plan Update, <br />nor the Environmental Impact Report, without addressing the concerns of residents and organizations <br />like Orange County Environmental Justice, Madison Park Neighborhood Association, THRIVE Santa <br />Ana, and Rise Up Willowick regarding the updated Plan's ability to effectively remediate soil -lead <br />contamination, air pollution, and the lack of open space in our city. We do not oppose passing the <br />Housing Element, since there is a strict timeline for that element, but we believe the individual <br />environmental justice policies of the General Plan must be revised, as they do not sufficiently <br />address the rampant environmental health issues that are poisoning our communities every <br />day. <br />OCEJ's concerns regarding the soil -lead policies, in particular, are as follows: <br />1. There are no provisions for the city to engage in soil -lead testing in residential <br />neighborhoods, and no clear process or agreed upon safety thresholds for identifying lead - <br />contaminated properties; <br />2. While Implementation Action 2.4 of the Safety Element expresses a commitment to <br />working with our organization to understand the prevalence of environmental lead <br />contamination in Santa Ana and to proposing solutions and measurements of effectiveness, <br />there is not an actual expressed commitment to remediating the lead. What's more, the <br />timeline limits the action to 2022--with a problem as widespread as soil -lead contamination, <br />one year is not enough time to effectively address the crisis; and <br />3. There is no commitment to collaborating with the Orange County Health Care Agency to <br />provide healthcare services for undocumented and uninsured residents living in <br />neighborhoods impacted by soil -lead contamination. <br />Furthermore, we demand that the city establish a permanent Environmental Justice office with <br />a public health expert on staff, to conduct regular meetings with residents and community <br />organizations to guide implementation of these policies, give regular reports on local <br />environmental health issues, and ensure a relationship of accountability and transparency <br />between the city and the community. <br />Additionally, the Environmental Impact Report should not be passed as is, because it does not <br />account for the fact that removing lead -based paint, as one of the General Plan provisions requires, <br />actually shakes lead loose into the air and substantially increases soil -lead contamination in the area. <br />Therefore, mitigation action on the city's part will be necessary to counteract this environmental <br />impact. Furthermore, by the Planning Department's own admission, the EIR's data is set to expire in <br />February 2022. An updated EIR with fresh data, community input on which neighborhoods are <br />designated as EJ Communities, and consideration for the impacts of lead paint removal <br />