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Catalog of City of Santa Ana Draft General Plan Update Comments Received Post February 15, 2022 <br />#Public Comments/Concerns Draft Policies and Implementation Actions Addressing Comments/Concerns City Response Source of Comment <br />93 Suggested Agency/Time Frame Change: Action S-2.4: PBA & CDA / Target <br />Year: 2022 Ongoing <br />Recommended Agency/Time Frame Change: PBA/CDA / Ongoing The comment is noted and is recommended to be included in its entirety. Alana M.W. LeBron, <br />et.al., UCI letter <br />dated March 11, 2022 <br />94 Suggested Action Change: Action CM-3.8: Environmental soil and human <br />health screening measures - Collaborate with Orange County Health Care <br />Agency and local stakeholders, such as Orange County Environmental Justice <br />and UC Irvine Public Health, in efforts to provide increased healthcare services <br />(i.e., blood lead testing, treatment) for residents of environmental justice <br />communities, including undocumented, uninsured, and under-insured <br />residents living in neighborhoods impacted by soil lead contamination and to <br />agree upon locally acceptable and enforceable safety thresholds for lead <br />exposure and contamination; collaborate to advocate for adjustment of the <br />County and State policies for health and environmental screening levels to <br />promote healthy outcomes related to lead contamination as recommended <br />by health experts. <br />Recommended Action Change: CM-3.8: Environmental Soil and Human Health Screening. <br />Collaborate with Orange County Health Care Agency and local stakeholders, such as Orange County <br />Environmental Justice and UC Irvine Public Health, in efforts to provide increased healthcare <br />services (i.e., blood lead testing, treatment) for residents, especially those that reside in <br />environmental justice communities. Additionally, collaborate to advocate for adjustment of the <br />County and State policies for health and environmental screening levels to promote healthy <br />outcomes related to lead contamination as recommended by health experts. <br />Action has been modified to reflect the spirit of the comment and to be inclusive of all persons <br />residing in Santa Ana regardless of group affiliation, legal status, or insurance type or lack <br />there of. Additionally, Orange County Health Care Agency (OCHCA) programs do not make a <br />distinction of anyone's legal or insurance status when providing services related to lead. <br />Alana M.W. LeBron, <br />et.al., UCI letter <br />dated March 11, 2022 <br />95 Suggested New Action: Action CN-XX: Lead contamination - Work with local <br />and regional partners, such as Orange County Environmental Justice, Orange <br />County Health Care Agency and University of California at Irvine Public Health, <br />to understand the prevalence, sources, and implications of lead <br />contamination of soil across Santa Ana. Collaborate with such local and <br />regional partners and environmental justice stakeholders in proposing, <br />selecting, and implementing solutions to mitigate (i.e., remove, cover, and <br />remediate) hazardous lead-contaminated soils in the city in a manner that <br />includes benchmarks (including but not limited to time benchmarks) and <br />routine monitoring of soil lead levels to measure and track effectiveness of <br />selected programs. <br />Recommended Action Change: S-2.4: Lead Contamination. Work with state, local and regional <br />partners, such as the Department of Toxic Substances Control, South Coast Air Quality District, <br />Orange County Environmental Justice, Orange County Health Care Agency and University of <br />California at Irvine Public Health, to understand the prevalence, sources, and implications of lead <br />contamination of soil across Santa Ana. Collaborate with such state agencies, local and regional <br />partners and environmental justice stakeholders in proposing, selecting, and implementing <br />measures to mitigate (i.e., remove, cover, and remediate) hazardous lead-contaminated soils in <br />the city in a manner that includes key benchmarks and routine monitoring of soil lead levels to <br />measure and track effectiveness of selected approach. <br />Action addressing lead contamination already exists in the Safety Element (S-2.4) and need not <br />be duplicate in different. <br />Alana M.W. LeBron, <br />et.al., UCI letter <br />dated March 11, 2022 <br />96 Suggested Action Change: Action LU-3.6: Lead paint abatement - Coordinate <br />with County of Orange Health Care Agency and community organizations to <br />strengthen local programs and initiatives to eliminate lead-based paint <br />hazards, with priority given to residential buildings located within <br />environmental justice area boundaries. When conducting lead paint <br />abatement, ensure that workers have proper physical protections; safeguard <br />other areas of the abated building or residence from lead or other toxins that <br />may be re-suspended in the air, soil, and dust; provide support for temporary <br />relocation of residents during abatement process; and monitor lead levels for <br />workers, residents, and the indoor and outdoor environment of the residence <br />that was abated. <br />N/A Workplace safety is already regulated by Cal/OSHA and is outside of the City's regulatory <br />authority. <br />Alana M.W. LeBron, <br />et.al., UCI letter <br />dated March 11, 2022 <br />97 Suggested New Action: Action LU-XX: Protect workers’ health during lead <br />paint abatement - Provide appropriate knowledge and protective gear and <br />equipment for workers certified as lead renovators when conducting <br />renovation activities. Ensure that trained workers have reasonable workloads <br />and time frames for completion of renovation activities. <br />N/A Workplace safety is already regulated by Cal/OSHA and is outside of the City's regulatory <br />authority. <br />Alana M.W. LeBron, <br />et.al., UCI letter <br />dated March 11, 2022 <br />98 Suggested Action Change: Action LU-3.18: Renovations and lead prevention - <br />Require contractor training and/or certification for safe work practices to <br />conduct residential renovations for pre-1978 structures that may contain <br />existing lead paint. <br />Existing Action: LU-3.18: Renovations and Lead Prevention. Evaluate the feasibility of requiring <br />contractor training and/or certification for safe work practices to conduct residential renovations <br />for pre-1978 structures that may contain existing lead paint. <br />Training for contractors should only be implemented once full analysis of costs and benefits to <br />the community have been thoroughly analyzed and already a part of the draft action. <br />Alana M.W. LeBron, <br />et.al., UCI letter <br />dated March 11, 2022 <br />Page 19