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Orozco, Norma <br /> From: Patricia Flores <patricia@ocej.org> <br /> Sent: Tuesday, December 21, 2021 4:00 PM <br /> To: eComment <br /> Subject: Re: Item 41, Santa Ana General Plan Update and Environmental Impact Report <br /> Dear Santa Ana City Council, <br /> I am writing to urge you to not pass the Environmental Justice provisions of the General Plan Update, nor the <br /> Environmental Impact Report, without addressing the concerns of residents and organizations like Orange <br /> County Environmental Justice, Madison Park Neighborhood Association, THRIVE Santa Ana, and Rise Up <br /> Willowick regarding the updated Plan's ability to effectively remediate soil-lead contamination, air pollution, <br /> and the lack of open space in our city. We do not oppose passing the Housing Element of the General Plan, <br /> since there is a strict timeline for that element, but we believe the individual environmental justice <br /> policies of the Plan must be revised, as they do not sufficiently address the rampant environmental health <br /> issues that are poisoning our communities every day. <br /> OCEJ's concerns regarding the soil-lead policies, in particular, are as follows: <br /> 1. There are no provisions for the city to engage in soil-lead testing in residential neighborhoods, and no clear <br /> process or agreed upon safety thresholds for identifying lead-contaminated properties; <br /> 2. While Implementation Action 2.4 of the Safety Element expresses a commitment to working with our <br /> organization to understand the prevalence of environmental lead contamination in Santa Ana and to proposing <br /> solutions and measurements of effectiveness, there is not an actual expressed commitment to remediating the <br /> lead. What's more, the timeline limits the action to 2022--with a problem as widespread as soil-lead <br /> contamination, one year is not enough time to effectively address the crisis; and <br /> 3. There is no commitment to collaborating with the Orange County Health Care Agency to provide healthcare <br /> services for undocumented and uninsured residents living in neighborhoods impacted by soil-lead <br /> contamination. <br /> Additionally, the Environmental Impact Report should not be passed as is, because it does not account for the <br /> fact that removing lead-based paint, as one of the General Plan provisions requires, actually shakes lead loose <br /> into the air and substantially increases soil-lead contamination in the area. Therefore, mitigation action on the <br /> city's part will be necessary to counteract this environmental impact. <br /> If City Council decides to vote on the General Plan Update and Environmental Impact Report today, please vote <br /> not to approve the Environmental Justice components of the plan without our recommended revisions, and do <br /> not approve the EIR without accounting for the increase in lead contamination that the Plan could cause. Failing <br /> to account for these issues will put the city in violation of California SB 1000, a dangerous move when the eyes <br /> of the California Attorney General's office are fixed on Santa Ana. If necessary, feel free to approve the <br /> Housing Element of the plan--but please, do not ignore these urgent health crises facing our community. <br /> Sincerely, <br /> Patrici J. Flores Yrarrazaval <br /> She/her/hers, they/them/theirs <br /> Project Director <br /> Orange County Environmental Justice (OCEJ) <br /> 2 <br />