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

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