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UNIVERSITY OF CALIFORNIA l Y' ✓< BERULEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE SAN DIEGO SAN FRANCISCO r SANTA BARBARA SANTA CRUZ rtla0' , Department of Environmental and Occupational Health Anteater Instruction &Research Bldg, Rm 2034 Program in Public Health Irvine, CA 92697-3957 (949)824-0548 (949)824-0529 FAX December 7, 2021 Santa Ana City Council 20 Civic Center Plaza Santa Ana, CA 92702 Re: Public Comment to Agenda Item #37 for December 7, 2021 Santa Ana City Council Meeting Dear Santa Ana City Councilmembers: Thank you for the opportunity to comment on the City of Santa Ana General Plan Update and the Final Recirculated Program Environmental Impact Report (FEIR). I am Professor of Environmental Health and Graduate Director of the Department of Environmental and Occupational Health, University of California, Irvine. My research focuses on population-based studies of environmental exposure assessment, environmental health, and environmental health disparity. I have been working with community partners in Santa Ana for the past few years on environmental injustice issues. I am writing to request that the City of Santa Ana 1) delay approval of the General Plan Update and certification of its accompanying FEIR; 2) work with communities to develop more comprehensive understanding of their environmental health concerns; and 3) incorporate pending resident concerns and suggestions in the General Plan that will make the City of Santa Ana more accountable in addressing the environmental injustice issues. Below are my top reasons for the requests. 1) The UCI Public Health researchers have been working with community organizations (i.e. Orange County Environmental Justice and Madison Park Neighborhood Association) on various environmental injustice issues, including soil lead contamination and air pollution problems at both outdoor environment and workplaces. The collaborative work revealed substantial concerns of elevated contaminant exposures being experienced by Santa Ana residents and workers. Exposure to multiple environmental hazards may lead to numerous adverse health outcomes including asthma, cardiovascular diseases, IQ loss, and cancer etc. However, the recent Santa Ana Community Survey was designed and administered inadequately, which forced residents to choose between environmental justice priorities and had only a 0.2% participation rate. Thus the results of the survey likely did not capture all of the environmental health issues concerning the residents. 2) The City Council has held a few round table discussions with the UCI and Orange County Environmental Justice on soil lead contamination in 2021. However, the proposed solutions were not incorporated in the General Plan Update. More specifically, we believe that the current soil-lead policies are insufficient for three reasons: • 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;