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<br />Verny Carvajal <br />October 6, 2020 <br />Page 3 <br /> <br /> <br />from private developers, among other sources. Id. However, the DPEIR fails to provide <br />any evidence that funding will be sufficient to reduce the City’s parkland deficiency such <br />that impacts would be less than significant. The DPEIR also asserts that the City’s park <br />shortage would be reduced by “private parks and recreational facilities owned and <br />maintained by homeowner associations.” Id. The DPEIR fails to note that many private <br />recreational facilities, like rooftop parks, are not open to the public and will do nothing to <br />improve park access for most of the City, especially lower-income residents. The <br />DPEIR’s unsupported conclusions and its failure to identify mitigation measures are <br />invalid under CEQA. <br /> <br />In order to achieve the City’s park standard and accommodate the needs of tens of <br />thousands of new City residents, additional park space is urgently needed, and the 102- <br />acre Willowick site can help meet this need. The Willowick Community Park proposal <br />calls for 90 acres to be set aside for public parkland, with the remaining 12 acres to be <br />developed as affordable housing. See Willowick Community Park Proposal at 17, 30. In <br />addition to serving growing citywide demand for parks, real recreational open space at <br />the Willowick site will also help meet the existing needs of nearby residents who <br />currently lack adequate access to green spaces in their neighborhoods. There are an <br />estimated 8,500 people living within a 10-minute walk of the Willowick site who <br />currently lack access to a nearby public park. See Willowick Community Park Proposal at <br />26. <br /> <br />Preserving most of the Willowick site as open space will also help to mitigate <br />environmental impacts associated with other aspects of the Update. The DPEIR indicates <br />that the proposed increases in intensity of development and population growth under the <br />Update are projected to generate significant impacts on air quality and greenhouse gas <br />emissions. DPEIR at 1-13, 1-25 (Table 1-4). Urban green spaces improve air quality and <br />mitigate climate change, as trees remove air pollutants and greenhouse gases from the air. <br />See David J. Nowak and Gordon M. Heisler, National Recreation and Parks Association, <br />Air Quality Effects of Urban Trees and Parks (2010), attached as Exhibit B; Erica Gies, <br />The Trust for Public Land, The Health Benefits of Parks (2006), attached as Exhibit C, at <br />13. Thus, maintaining Willowick as green space can mitigate air quality and climate <br />impacts. <br /> <br />Willowick’s role in air quality mitigation is especially important because <br />neighborhoods adjacent to the site have high levels of certain air pollutants, including PM