CORRESPONDENCE - #37 - Laserfiche WebLink

Home Browse Search

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