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Memo to City of Santa Ana Planning Commission September 15, 2021 Page 2 As used in the Open Space Element, "park deficient area" means "a geographic area which is located more than 0.25 miles from the nearest public park of 5 acres or less and more than 0.5 miles from the nearest public park larger than 5 acres as measured along the shortest available pedestrian route." This is a modified version of the definition used in the August 2021 Recirculated Draft Program Environmental Impact Report (RDPEIR) for the General Plan Update. RDPEIR at 5.15-12, 5.15-13.1 We propose modifying the Open Space Element to define "environmental justice area" as follows: As used in the Open Space Element, "environmental justice area" means "a disadvantaged community as defined by Government Code Section 65302(h)(4)(A), i.e. a low-income area that is disproportionately affected by environmental pollution and other hazards that can lead to negative health effects, exposure, or environmental degradation, or an area identified by the California Environmental Protection Agency pursuant to Section 39711 of the Health and Safety Code." This definition of"environmental justice area" is consistent with the RDPEIR, which references SB 1000's definition of"disadvantaged community." Gov. Code § 65 3 02(h)(4)(A); RDPEIR at 4.15-4.16, 5.15-12, 5.15-15. The California Environmental Protection Agency has identified 23 census tracts in Santa Ana as environmental justice communities because they have received a California Communities Environmental Health Screening (CalEnviroScreen) composite score greater than 75 percent. RDPEIR at 2-19, 4-15. 2. Proposed Addition of"No Net Loss of Open Space" Policy in General Plan Update We propose the addition of a "no net loss of open space" policy in the Open Space Element: Policy OS-1.14: No Net Loss of Open Space. There shall be no net loss of Open Space in the city, excluding any acreage of a golf course that is redeveloped solely for 100%below-market rate housing. Any Open Space lost due to development shall be replaced at a ratio of at least 1:1. i The RDPEIR maps park deficient areas using aerial linear distances to the closest park, rather than actual on-the-ground walking distances, which are typically longer due to a lack of direct routes. We propose using on-the-ground walking distances.