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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 />137 Lead Action Plan. MPNA requests that the City create an aggressive action
<br />plan to address the soil-lead contamination in Santa Ana EJ Communities that
<br />is backed with clear, enforceable measures. a) While the City plans to address
<br />some aspects of lead-based paint contamination, it has neglected historical
<br />emissions of leaded gasoline. 2. Mitigation Measures. MPNA requests that the
<br />City analyze and provide mitigation measures for the increased soil-
<br />contamination that can occur from the demolition or removal of existing
<br />buildings that contain lead-based paint.
<br />A number of policies and actions address this comment. The Draft Plan includes numerous actions aimed at addressing lead based contamination in
<br />the community, which were developed in partnership with community stakeholders. Lead
<br />contamination from non stationary sources like automobiles is a statewide problem and
<br />especially acute in urban environments where vehicle traffic is heaviest. The plan includes
<br />actions to help identify the exact cause of the pollution and to then seek funds to assist with
<br />remediation. The plan also includes actions to provide education related to renovations and
<br />construction on buildings that may have lead based products to reduce risk of lead poisoning.
<br />Actions addressing lead contamination include S-2.4, LU-3.6, LU-3.17, LU-3.18, LU-3.19, LU-
<br />3.20, LU-3.21, LU-3.22, LU-3.24, LU-3.26, and LU-3.29.
<br />MPNA Attachment II,
<br />2.18.22
<br />138 Mitigation Measures. MPNA requests that the City analyze and provide
<br />mitigation measures for the increased soil-contamination that can occur from
<br />the demolition or removal of existing buildings that contain lead-based paint.
<br />Recommended Action Change: LU-3.26: Health Conditions. Work with state agencies including
<br />Department of Toxic Substances Control and South Coast Air Quality Management District, Orange
<br />County Health Care Agency and local stakeholders including Orange County Environmental Justice
<br />and UC Irvine Public Health to identify baseline conditions for lead soil and air contamination in
<br />Santa Ana, routinely monitor indicators of lead such contamination, and measure positive
<br />outcomes. Collaborate with these organizations to secure grant funds for soil and air testing,
<br />remediation (e.g., bioremediation, covering, removing, air filtration), and prevention activities for
<br />residential properties in proximity to sites identified with high soil lead levels of soil pollution
<br />(including sites identified with soil lead levels of 80 ppm or higher), and air pollution , with a focus
<br />on communities disproportionately affected by soil contamination.
<br />Action has been modified to address frequency of soil monitoring, examples of remediation
<br />and emphasis on communities disproportionally affected by soil contamination. Per March 28,
<br />2022 roundtable, new revisions related to soil and air included in response to MPNA
<br />comments to broaden collection of baseline conditions. Reference to 80 ppm added in
<br />response to OCEJ comments in context of pursuing grant funding.
<br />MPNA Attachment II,
<br />2.18.22
<br />139 Baseline Pollution studies and Progress Reports. MPNA requests that the City
<br />publish data establishing a clear baseline of pollution that exists today that
<br />affects communities, specifically EJ communities. 3 a) The data should be
<br />published yearly to track the effectiveness and weaknesses of the GPU and
<br />should be presented at EJ Community Meetings.
<br />Existing Action: CN-3.3: Health Metrics. Engage with the Orange County Health Care Agency and
<br />other stakeholders to monitor key health indicators to measure the success of the outcome of
<br />General Plan policies and the implementation plan, including reduction in incidence in asthma and
<br />low birth weight of infants.
<br />Once established through proposed Action CN-1.10, an interagency team focused on EJ issues
<br />can evaluate all existing studies, monitoring and reporting systems conducted by established
<br />hazardous material regulating agencies relevant to Santa Ana, and publish through proposed
<br />Environmental Quality webpage and start to evaluate health indicators to track effectiveness.
<br />MPNA Attachment II,
<br />2.18.22
<br />140 1,000 Feet Minimum Buffer-Zones. MPNA requests that the City commit to
<br />creating buffer zones of at least 1,000 feet between industrial uses and
<br />sensitive receptors. a) Currently POLICY LU-3.11 states “Promote landscaping
<br />and other buffers to separate existing sensitive uses from rail lines, heavy
<br />industrial facilities, and other emissions sources. As feasible, apply more
<br />substantial buffers within environmental justice area boundaries.” However,
<br />the policy has no detailed, enforceable language. b) The GPU should explicitly
<br />require this 1,000 feet minimum buffer-zone.
<br />Existing Action: LU-3.2: Design Guidelines and Standards. Update the zoning code's development
<br />and operational standards for industrial zones to address incompatibility with adjacent uses,
<br />including minimum distance requirements to buffer heavy industrial uses from sensitive receptors.
<br />Conduct a study to evaluate and establish appropriate minimum distances and landscape buffers
<br />between polluting industrial uses from sensitive receptors such as residences, schools, day care,
<br />and public facilities.
<br />Further analysis is required to determine what the appropriate buffer should be. If adopted,
<br />Action LU-3.2 will establish a process by which to study relevant data and best practices, to
<br />arrive at an appropriate distance, not simply choosing an arbitrary distance.
<br />MPNA Attachment II,
<br />2.18.22
<br />141 Air Quality Enforceability. MPNA requests that the City incorporate language
<br />into the GPU that: a) Prioritizes EJ Communities b) Commits to
<br />initiate/implement its actions c) Defines when these actions would be
<br />triggered d) Commits to address incompatible land uses with EJ Communities.
<br />Existing Action: LU-3.3: Healthy Lifestyles. Collaborate with residents and industry stakeholders to
<br />create a program to incentivize and amortize the removal of existing heavy industrial uses adjacent
<br />to sensitive uses.
<br />There are 75 actions directly addressing EJ issues in the Draft Plan. The action/program table
<br />states what the City is committing to and when the action/program is expected to be
<br />completed. The Draft Plan also commits to establishing a buffer between heavy industrial uses
<br />and residences, and exploring incentives/amortization program to reduce conflicts between
<br />the two uses.
<br />MPNA Attachment II,
<br />2.18.22
<br />142 The City must ensure the implementation of the GPU reduces and eliminates
<br />air emissions in EJ Communities. a) These problems are described in more
<br />detail in “Attachment A – MPNA Comments on the GPU” from our letter
<br />submitted as public comment titled “Comments on the City of Santa Ana’s
<br />General Plan Update” from October 29, 2020.
<br />A number of policies and actions address this comment. As depicted in the CalEnviroScreen tool, air pollution is not contained within city borders,
<br />rather, is shaped by regional forces as well as topographical variations. As such, there are
<br />regional and state agencies tasked with tackling air pollution. There are numerous policies and
<br />actions in the Draft Plan to ensure Santa Ana is doing its part locally and regionally to reduce
<br />air pollution. To see related actions see draft actions LU-3.2, LU-3.3, LU-3.4, LU-3.15, LU-3.23,
<br />LU-4.6, CN-1.1, CN-1.4, CN-1.5, CN-1.6, CN-1.7,CN-1.9, CN-1.12, CN-1.17, S-2.1, S-2.2, M-5.8,
<br />and draft policies m-1.7, CN-1.1, CN-1.3, CN1.15, CN-1.16, CN-1.18, OS-2.5, LU-3.12, and LU-
<br />4.3.
<br />MPNA Attachment II,
<br />2.18.22
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