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school students in the San Francisco School District to the smoking rates of high school students in seven other metropolitan school districts located in cities that did not have a flavored tobacco ban. According to the study, the smoking rate for San Francisco high school students under the age of 18 increased from 4.7% in 2017 before the adoption of the city's ordinance to 6.2% in 2019,the year after the ordinance was enacted. This is a 32% increase in underage youth cigarette smoking rates in the San Francisco school district. At the same time, the underage smoking rates in the other metropolitan school districts that are located in cities which did not have a flavored tobacco product sales ban continued to decline and averaged 2.8% as of 2019. Link:https://jamanetwork.com/journals/jamapediatrics/fullarticle/2780248?utm source=twitter&utm cam paign=content- shareicons&utm content=article engagement&utm medium=social&utm term=052421&s=03#.YKwb0 ZyP66Y.twitter Study No. 3: Milken Institute School of Public Health, George Washington University, Nicotine & Tobacco Research (July 31, 2021): A third study, funded by the US National Cancer Institute and conducted through the Milken Institute School of Public Health at George Washington University, found similar impacts from flavored vapor bans on young adult tobacco users. The study compiled young adult smoking rates in six major metropolitan cities that enacted a flavored tobacco product ban. The study abstract included the following findings: Moreover, if vape product sales were restricted to tobacco flavors, 39.1% of users reported being likely to continue using e-cigarettes but 33.2% were likely to switch to cigarettes.If vape product sales were entirely restricted, e-cigarette users were equally likely to switch to cigarettes versus not 40%). Link: https://doi.org/10.1093/ntr/ntabl54 Low and Declining Use Rates of Traditional Tobacco Products Require Caution in Flavor Bans: According to California's Healthy Kids Survey for 2020-2021 in Santa Ana Unified School District, only 2% of I Ith graders had ever smoked a whole cigarette and 0% had not done so, even once, in the past 30 days; only 1%had ever tried smokeless tobacco and 0%currently do not use smokeless tobacco. The same survey found that in 2019, 9% of 1 1th graders currently used e-cigarettes. That figure should be considered in the context of recent findings by the FDA that e-cigarette use among youth declined about one-third in 2020,and declined sharply again in 2021,such that nationally,current e-cigarette use among high schoolers is at 11.3%, about a 60% decrease from two years earlier. See E-Cigarette Use Among Middle and High School Students —National Youth Tobacco Survey, United States, 2021, US Department of Health and Human Services, Centers for Disease Control and Prevention, Morbidity and Mortality Weekly Report, October 1, 2021, Vol. 70,No. 39. This means that the empirical data showing essentially no underage use of traditional products in Santa Ana and the national trend of a 60%drop in e-cigarette use does not support the wholesale banning of all flavored tobacco products that legal age adults prefer to use. FDA Intends to Ban Menthol Cigarettes and Flavored Cigars: The City of Santa Ana should not pursue a flavored tobacco ban ordinance because the Food and Drug Administration announced in April of this year that the agency intends to publish a rule banning the sale of menthol cigarettes and all flavored cigars. With such a sweeping regulation, the city council should pause and allow the FDA's proposed regulation process which the agency intends to ban some of the same flavored tobacco products that would be prohibited under the proposed ordinance. National Association of Tobacco Outlets,Inc.,17595 Kenwood Trail,Minneapolis,MN 55044 952-683-9270 www.natocentral.org