CORRESPONDENCE - #26 - Laserfiche WebLink

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Orozco, Norma From: Patricia Flores <patricia@ocej.org> Sent: Tuesday, February 15, 2022 3:56 PM To: eComment Subject: Re: Item 26, Santa Ana General Plan Update and Environmental Impact Report Dear Santa Ana City Council: I am writing to urge you to not pass the Environmental Justice provisions of the General Plan Update, nor the Environmental Impact Report, without addressing the concerns of residents and organizations like Orange County Environmental Justice, Madison Park Neighborhood Association, THRIVE Santa Ana, and Rise Up Willowick regarding the updated Plan's ability to effectively remediate soil-lead contamination, air pollution, and the lack of open space in our city. We do not oppose passing the Housing Element, since there is a strict timeline for that element, but we believe the individual environmental justice policies of the General Plan must be revised, as they do not sufficiently address the rampant environmental health issues that are poisoning our communities every day. OCEJ's concerns regarding the soil-lead policies, in particular, are as follows: 1 . 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; 2. While Implementation Action 2.4 of the Safety Element expresses a commitment to working with our organization to understand the prevalence of environmental lead contamination in Santa Ana and to proposing solutions and measurements of effectiveness, there is not an actual expressed commitment to remediating the lead. What's more, the timeline limits the action to 2022--with a problem as widespread as soil-lead contamination, one year is not enough time to effectively address the crisis; and 3. There is no commitment to collaborating with the Orange County Health Care Agency to provide healthcare services for undocumented and uninsured residents living in neighborhoods impacted by soil-lead contamination. Furthermore, we demand that the city establish a permanent Environmental Justice office with a public health expert on staff, to conduct regular meetings with residents and community organizations to guide implementation of these policies, give regular reports on local environmental health issues, and ensure a relationship of accountability and transparency between the city and the community. Additionally, the Environmental Impact Report should not be passed as is, because it does not account for the fact that removing lead-based paint, as one of the General Plan provisions requires, actually shakes lead loose into the air and substantially increases soil-lead contamination in the area. Therefore, mitigation action on the city's part will be necessary to counteract this environmental impact. Furthermore, by the Planning Department's own admission, the EIR's data is set to expire in February 2022. An updated EIR with fresh data, community input on which neighborhoods are designated as EJ Communities, and consideration for the impacts of lead paint removal 1