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Health & Fitness

Part 2: The Big Rocks in the General Plan Update

What are the important points in the draft General Plan Update Public Health element?

Encinitas General Plan Update: Public Health Element 

This ison the Encinitas General Plan Update. For each element, I am applying a parable about time management, describing how to fill a jar with rocks.  You need to put the biggest rocks (the most important things) in the jar first, before adding pebbles, gravel and sand.  If you put the sand in first, there won’t be room for the big rocks. 

With respect to the Encinitas General Plan Update Public Health Element, in 45 pages, there are lots of topics, many of them information-only, not actual General Plan material; most of them covered elsewhere; and some of them downright inexplicable.  So I ask, what are the “big rocks”?  Without rewriting the entire chapter, I want to propose the key points that need to be clearly stated to protect and serve our community.

Overall: while nobody would oppose the concept of promoting public health, this element does not provide clear, long-range policy guidance for the City.  The introductory section documents that Encinitas, relatively speaking, is a healthy community. We do not suffer any major public health deficiencies.  Section 1 calls for health to be a “City priority,” implying that health is more important than something else - possibly other policy foci such as public safety, environment, or fiscal responsibility.  Whether or not it was intended, it is inappropriate to suggest that health should have priority in all policies (Section 1.4).  If every GPU element advocates for its topic to be a priority, then there are no priorities because everything is a priority.  Other sections advocate incentives and “support” without acknowledging policies that already exist or limitations of City authority (e.g., 2.1 – waiving booth fees for health advocates when City policy already gives discounts for non-profits advocating on any issue).   Finally, there are issues in this draft that far overreach what is appropriate in a city’s General Plan (e.g., 3.5 – increasing the number of private health clubs; 6.2 – mandating farmer’s markets three times per week; 8.11 – promoting reusable bags in dry cleaning establishments).

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What is important and appropriate for inclusion in the Encinitas General Plan is stricter environmental health regulation, especially attention to development of properties with toxic agricultural chemicals.  It does not seem that this issue is adequately addressed anywhere else in the GPU draft.  And this is an area where the City has responsibility and where public health is already at risk.  Specific comments on this part of the Public Health Element are below:

  • Article 3.2 calls for a “Development Project Checklist” to be used to analyze health impacts of development proposals.  To the extent that such a checklist does not already exist, it should be created (or compiled from diverse sources) and should explicitly include toxic soils.
  • Section 8.1 Pesticides on Agricultural Land, states:  “Create and periodically update a master database of local agricultural land, nurseries and greenhouses. To the extent feasible, include information on soil quality (e.g., pesticide contamination) and any other historic health related hazards so the City has accurate information to use when considering new development proposals or soil mitigation projects.” Information on which land is used for agricultural purposes should already be known through city and county tax records.  If not, it surely needs to be created and maintained.  Information on pesticide contamination also should already exist as a result of requirements to register toxic chemicals.  The plan must require (deleting “to the extent feasible”) that the City have access to this information, whether through arrangements with the county and state or by collecting the information directly. 
  • Further, section 8.1 states that “A materials analysis (degree of contamination, scope of treatment, remediation and/or disposal measures) should be considered, initiated and documented in conjunction with the preliminary design, project review and construction.”  Stronger language is needed:  a materials analysis must be required.  The plan language can be simplified and strengthened.  Instead of calling for the City to “Develop a process to keep adjacent residents informed and protected throughout the stages of development, …” the City should commit simply to “inform and protect residents….”  What we want is not a process – what we want is information and protection.
  • Section 8.6 calls for reducing the use of pesticides in public parks.  The City already has a policy of using integrated pest management and other best management practices.
  • Section 8.10 requires that the City use “green” cleaning supplies.  The term “green” is undefined and often used as a label without any meaningful environmental standards.  Mandating the use of non-toxic cleaning supplies is fine, though it’s not clear this belongs in the General Plan. 
  • Section 8.13 says, “To the extent feasible, avoid locating new sensitive uses such as schools, childcare centers and senior housing in proximity to sources of pollution (e.g., I-5, truck routes and busy roadways).”  If adopted, this would impact plans for development of the Encinitas Community Park, which is designed for use by children and seniors and is in close proximity to I-5.
  • Section 8-14 appears to weaken our commitment to regional air quality monitoring and climate action.  This is not acceptable.

As we review other elements, we should ensure that the useful parts of the Public Health Element draft are adequately covered.  Having one element to tell us to follow another element (e.g., 4.2 – “Implement the goals and policies in the Housing Element that encourage diverse and affordable housing”) is redundant and confusing.  Does it imply that the goals and policies of other elements not specifically called out should NOT be implemented?

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There is much to learn and address in this draft element. However, it needs significant editing, with the environmental health section strengthened.

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