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UCI School of Social Sciences Department of AintlhiropolloqV 3151 Social Science Plaza Irvine,CA 92691-5100 (949)824-1207 httl2s://www.anthrol2olog3:.uci.edu December 7, 2021 Re: Environmental Justice in Santa Ana's General Plan Update Dear Mayor Sarmiento and Santa Ana City Council, Thank you for the opportunity to comment on the City of Santa Ana's Draft General Plan Update. I am a PhD Candidate at the University of California Irvine specializing in environmental justice policy issues in Southern California, and my dissertation research focuses on SB 1000 implementation in Santa Ana. I have had the pleasure of working closely as a research collaborator with community organizations in Santa Ana since 2014, most recently with MPNA-GREEN's community air monitoring initiative. I am writing to express my serious concerns with the Draft General Plan Update and to urge the City Council not to adopt the GPU at today's City Council meeting. As a blueprint for the next several years of the City's development, this document should ensure inclusiveness, transparency, and accountability. 1. It is antithetical to the environmental justice principles to approve the General Plan Update in a meeting that is not accessible to all Santa Ana residents. Robust, inclusive, and equitable community engagement is the cornerstone of environmental justice. While the City has made important strides in improving community outreach about EJ in the General Plan since last fall, when the state Department of Justice endorsed a delay in the planning process, the current General Plan falls short of reflecting the voices and interests of the city's 17 disadvantaged communities. For one immediate and crucial example, remote participation in city meetings by Zoom and phone is no longer available to residents, despite ample evidence throughout the pandemic that these options are both feasible and essential for community engagement. 2. The General Plan Update should establish procedures and expectations for transparency and accountability regarding historical, ongoing, and future environmental hazards impacting Santa Ana's disadvantaged communities. In the course of my work with MPNA-GREEN and UCI researchers, we have encountered a serious lack of transparency about industrial permits and permit violations. MPNA-GREEN and numerous community leaders have recommended several measures to ensure transparency and accountability, including: a. Collection and publication of baseline data on emitters, emissions, and concentrations for each disadvantaged community, b. Specific, goal-oriented remediation plans for each disadvantaged community 1