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UNIVERSITY OF CALIFORNIA <br />BERULEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE • SAN DIEGO • SAN FRANCISCO <br />Department of Environmental and Occupational Health <br />Program in Public Health <br />December 7, 2021 <br />Santa Ana City Council <br />20 Civic Center Plaza <br />Santa Ana, CA 92702 <br />r SANTA BARBARA SANTA CRUZ <br />.a <br />a <br />tlnB <br />Anteater Instruction & Research Bldg <br />Irvine, CA 92697-3957 <br />(949) 824-0548 <br />(949) 824-0529 FAX <br />Re: Public Comment to Agenda Item #37 for December 7, 2021 Santa Ana City Council <br />Meeting <br />Dear Santa Ana City Councilmembers: <br />Thank you for the opportunity to comment on the City of Santa Ana General Plan Update and <br />the Final Recirculated Program Environmental Impact Report (FEIR). I am Professor of <br />Environmental Health and Graduate Director of the Department of Environmental and <br />Occupational Health, University of California, Irvine. My research focuses on population -based <br />studies of environmental exposure assessment, environmental health, and environmental health <br />disparity. I have been working with community partners in Santa Ana for the past few years on <br />environmental injustice issues. <br />I am writing to request that the City of Santa Ana 1) delay approval of the General Plan <br />Update and certification of its accompanying FEIR; 2) work with communities to develop <br />more comprehensive understanding of their environmental health concerns; and 3) <br />incorporate pending resident concerns and suggestions in the General Plan that will <br />make the City of Santa Ana more accountable in addressing the environmental injustice <br />issues. Below are my top reasons for the requests. <br />1) The UCI Public Health researchers have been working with community organizations (i.e. <br />Orange County Environmental Justice and Madison Park Neighborhood Association) on <br />various environmental injustice issues, including soil lead contamination and air pollution <br />problems at both outdoor environment and workplaces. The collaborative work revealed <br />substantial concerns of elevated contaminant exposures being experienced by Santa Ana <br />residents and workers. Exposure to multiple environmental hazards may lead to numerous <br />adverse health outcomes including asthma, cardiovascular diseases, IQ loss, and cancer <br />etc. However, the recent Santa Ana Community Survey was designed and administered <br />inadequately, which forced residents to choose between environmental justice priorities and <br />had only a 0.2% participation rate. Thus the results of the survey likely did not capture all of <br />the environmental health issues concerning the residents. <br />2) The City Council has held a few round table discussions with the UCI and Orange County <br />Environmental Justice on soil lead contamination in 2021. However, the proposed solutions <br />were not incorporated in the General Plan Update. More specifically, we believe that the <br />current soil -lead policies are insufficient for three reasons: <br />• 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 <br />lead -contaminated properties; <br />Rm 2034 <br />