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