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<br />Memo to City of Santa Ana Planning Commission <br />September 15, 2021 <br />Page 2 <br /> <br /> <br />As used in the Open Space Element, “park deficient area” means “a geographic <br />area which is located more than 0.25 miles from the nearest public park of 5 acres <br />or less and more than 0.5 miles from the nearest public park larger than 5 acres as <br />measured along the shortest available pedestrian route.” <br /> <br />This is a modified version of the definition used in the August 2021 Recirculated <br />Draft Program Environmental Impact Report (RDPEIR) for the General Plan Update. <br />RDPEIR at 5.15-12, 5.15-13.1 <br /> <br />We propose modifying the Open Space Element to define “environmental justice <br />area” as follows: <br /> <br />As used in the Open Space Element, “environmental justice area” means “a <br />disadvantaged community as defined by Government Code Section <br />65302(h)(4)(A), i.e. a low-income area that is disproportionately affected by <br />environmental pollution and other hazards that can lead to negative health effects, <br />exposure, or environmental degradation, or an area identified by the California <br />Environmental Protection Agency pursuant to Section 39711 of the Health and <br />Safety Code.” <br /> <br />This definition of “environmental justice area” is consistent with the RDPEIR, <br />which references SB 1000’s definition of “disadvantaged community.” Gov. Code § <br />65302(h)(4)(A); RDPEIR at 4.15-4.16, 5.15-12, 5.15-15. The California Environmental <br />Protection Agency has identified 23 census tracts in Santa Ana as environmental justice <br />communities because they have received a California Communities Environmental <br />Health Screening (CalEnviroScreen) composite score greater than 75 percent. RDPEIR <br />at 2-19, 4-15. <br /> <br />2. Proposed Addition of “No Net Loss of Open Space” Policy in General Plan Update <br />We propose the addition of a “no net loss of open space” policy in the Open Space <br />Element: <br /> <br />Policy OS-1.14: No Net Loss of Open Space. There shall be no net loss of Open <br />Space in the city, excluding any acreage of a golf course that is redeveloped <br />solely for 100% below-market rate housing. Any Open Space lost due to <br />development shall be replaced at a ratio of at least 1:1. <br /> <br /> <br />1 The RDPEIR maps park deficient areas using aerial linear distances to the closest park, <br />rather than actual on-the-ground walking distances, which are typically longer due to a <br />lack of direct routes. We propose using on-the-ground walking distances.