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

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In addition to our critiques of the content of the survey, we also feel that the city did not effectively outreach to the community to ensure their participation in the process. Out of Santa Ana's 332,318 residents, only 746 completed the survey, or about 0.2% of our total population. This does not constitute an accurate assessment of our communities' environmental justice needs. We, along with many other residents and community stakeholders, believe that a more thorough community engagement process is needed to better inform the update to the City's General Plan. While we also appreciate that the City Planning Department invited our Collaborative to a series of meetings to present our research and inform policies to address the soil -lead crisis, ultimately, very few of our proposed solutions were incorporated into the GPU. The soil -lead policies that were adopted are insufficient, because: 1. There are no provisions for the city to engage in soil -lead testing in residential neighborhoods, and no clear process or agreed upon safety thresholds for identifying lead -contaminated properties; 2. While Implementation Action 2.4 of the Safety Element expresses a commitment to working with our organization to understand the prevalence of environmental lead contamination in Santa Ana and to proposing solutions and measurements of effectiveness, there is not an actual expressed commitment to remediating the lead. What's more, the timeline limits the action to 2022--with a problem as widespread as soil -lead contamination, one year is not enough time to effectively address the crisis; and 3. There is no commitment to collaborating with the Orange County Health Care Agency to provide healthcare services for undocumented and uninsured residents living in neighborhoods impacted by soil - lead contamination. In addition, there are no provisions ensuring that Santa Ana residents are prioritized for jobs to remediate lead contamination, and that they are provided proper protective equipment and living wages; and prioritizing bioremediation over removal of contaminated soils, to save money and avoid moving contaminated soils into other communities. All of these policies are of dire importance, in order to finally put an end to the poisoning of our residents, and to ensure that the city's response to this crisis addresses the negative health effects that our communities are already suffering. Furthermore, the Santa Ana City Council recently passed the Santa Ana Public Health and Climate Emergency Resolution, which commits the city to "implementing policies to remediate lead and other environmental toxins, in tandem with renter protections to ensure that remediated households are not displaced as a result of environmental clean up efforts." The General Plan Update is the perfect opportunity to put this resolution into action. While the City has committed in the latest draft of the General Plan to work with our Collaborative and the Orange County Health Care Agency (OC HCA) to advocate for more stringent lead screening measures at the local and state levels, as well as to discuss proposed solutions for remediating soil -lead and to increase access to blood -lead testing for Santa Ana residents, these activities are limited to 2022 in the listed timeframe. These are projects that will require an ongoing effort over several years to accomplish, and the city must commit to continuing this work beyond next year if we hope to effectively address lead contamination in Santa Ana. In order to ensure that the final version of the General Plan genuinely reflects the perspectives and needs of Santa Ana residents and expert community stakeholders, we request that the City participate in an additional series of roundtable discussions with impacted residents and community groups such as our own, in order to confirm their approval of the current policy language and incorporate any pending resident concerns. We also request an additional, specific meeting to discuss incorporating more comprehensive policies to address environmental lead contamination, especially considering the recent passage of the Santa Ana Public Health and Climate Emergency Resolution. In this way, we can collaboratively develop a robust General Plan that effectively addresses the numerous environmental justice and health concerns of our residents, and ensures that those communities most impacted by these issues can heal from this crisis, and thrive in Santa Ana for generations to come. Thank you for your time and consideration. Sincerely, Patricia J. Flores Yrarrazaval Project Director Orange County Environmental Justice Jun Wu, PhD Professor University of California, Irvine Alana LeBron, PhD Assistant Professor University of California, Irvine Juan Manuel Rubio, PhD Mellon Faculty Fellow University of California, Irvine