Item 37 - EIR No. 2020-03 and GPA No.2020-06 Santa Ana General Plan Update

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MIN � � � M, 3151 Social Science Plaza Irvine, CA 92691-5100 (949) 824-1207 https://www.anthropology.uci.edu December 7, 2021 Re: Environmental Justice in Santa Ana's General Plan Update To Whom It May Concern, Thank you for the opportunity to comment on the City of Santa Ana's Draft General Plan Update. I am Kim Fortun, Professor of Anthropology at University of California Irvine. For over thirty years, my research has focused on environmental injustice in settings around the world. Since 2017,1 have studied environmental injustice across California. The City of Santa Ana has many, largely unrecognized environmental hazards. I applaud the initiatives of the Santa Ana City Council to address these hazards in coming years. Passage of a new General Plan provides important opportunities to detail these initiatives. Many aspects of Santa Ana pose special environmental justice challenges, yet aren't adequately addressed (if at all) in the City's "II::::nv' iron irneintall Jusfiice I adle it ,aa,in,��,,,, a,in,��,,,, Ait a siis for the General Hain Update. • The city has important industrial facilities but they aren't dramatically visible to citizens (like the refineries in Wilmington, for example). These facilities release pollution into air and water every day, to an extent not yet adequately characterized. Some of the facilities also have potential for "worst case scenarios'' in which a large amount of toxic chemicals would be released off site into adjacent communities, with devastating effects. The US Environmental Protection Agency has identified six facilities with worst case scenario potential in Santa Ana (see thus Hst). Many of the facilities are very near homes and schools. Worst case scenarios are not addressed in the City's environmental justice analysis linked to above. • The city is nestled among many freeways and has many schools and care facilities very near to freeways. The City is also cross -cut with many heavily traveled boulevards. A growing body of research points to serious health effects of near -roadway pollution, pointing to the need for new approaches to zoning and heightened use of green cover for air quality control. This research has guidance for urban planning. (See, for example, this recenfl ubrshed resew ch . While greening is mentioned in the above environmental injustice analysis, special proposals advanced by community groups in Santa Ana have not been included. These include increased acreage of green space per resident and requirements for green walls and roofs. • Orange County and the City of Santa has gained national attention for pollution of water sources with PFOA ("forever chemicals," which have serious health effects). (See this L.A T runes coven aye). The special challenges of addressing PFOA pollution (and potential increases in water costs for residents and businesses) are not included in the City environmental justice analysis linked to above.