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Santa Ana City Council <br />December 7, 2021 <br />Page 3 <br />OCEJ urges the City Council to delay adoption of the General Plan Update <br />and the FEIR until the City can implement an adequate community survey that will <br />adequately capture concerns from the wider Santa Ana community. <br />II. The General Plan Update's Environmental Justice Policies Addressing Lead <br />Contamination Are Inadequate. <br />The inadequate community survey led to a flawed, narrow framing of <br />proposed General Plan policies. Had the City properly engaged in a thorough community <br />survey, the results of the soil -lead contamination assessment would have provided <br />additional support for the policies community stakeholders like OCEJ, Thrive Santa Ana, <br />and Rise Up Willowick continue to propose to the City. <br />Moreover, the General Plan Update's lead contamination policies do not <br />satisfy the spirit of Senate Bill 1000 ("SB 1000"), which requires incorporating <br />environmental justice policies into a General Plan Update and ensuring these policies <br />adequately address health risks to environmental justice communities. Gov. Code <br />§ 65302(h)(1)(A). While the City has complied with the former requirement, it has not <br />yet satisfied the latter. As the California Department of Justice ("DOJ") previously noted <br />in its own comment letters, the City's lackluster policies do not match the severity of the <br />lead contamination burdens and unique needs of the disadvantaged communities in its <br />jurisdiction as SB 1000 requires. Gov. Code § 65302(h)(1)(C). DOJ also agrees that the <br />City must do more to incorporate community input. <br />OCEJ reiterates the following concerns: <br />First, the General Plan Update does not include any provisions that require, <br />or even encourage, the City to engage in testing soils in residential neighborhoods for <br />lead contamination. Additionally, there is no clear process or agreed upon safety <br />thresholds for identifying lead -contaminated properties. <br />Second, proposed soil -lead contamination policies only provide superficial <br />commitment of City resources. Comprehensively remediating soil -lead contamination <br />and lead toxicity will require an ongoing effort over several years. Yet, proposed <br />solutions for remediating soil -lead contamination and to increase access to blood testing <br />for Santa Ana residents are set to expire in 2022. See RPDEIR Appendix B-a at 4-6, 63. <br />Effectively addressing lead contamination in Santa Ana will require more than just one <br />year of work, partnerships, and commitment. <br />Finally, the City continues to ignore OCEJ's healthcare policy <br />recommendations that will best serve Santa Ana's environmental justice communities. <br />1-1UIL)M111AV_Y <br />