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Verny Carvajal October 6, 2020 Page 4 2.5.1 Urban green spaces like Willowick also help mitigate the urban heat island effect, significantly reducing temperatures in surrounding neighborhoods. See The Trust for Public Land, The Heat Is On (2020), attached as Exhibit D. Open space at the Willowick site may also help mitigate impacts on water quality and hydrology resulting from the Update, such as stormwater runoff impacts associated with new development. The DPEIR concludes that the Update's water quality and hydrology impacts would be less than significant and that no mitigation is needed. DPEIR at 5.9-29, 5.9-32. However, this conclusion improperly relies on asserted compliance with applicable state, regional, and local regulatory requirements. DPEIR at 5.9-30 to 5.9-32. Regulatory compliance does not determine the significance of impacts and cannot be used to bypass the City's obligation to analyze and mitigate those impacts. See Californians for Alternatives to Toxics v. Department of Food&Agriculture (2005) 136 Cal.AppAth 1, 15-17; Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal.AppAth 1099, 1108-09. IL The Update does not provide for sufficient affordable housing and would undermine the City's Housing Opportunity Ordinance. Santa Ana faces a growing shortage of affordable housing, especially of deeply affordable units. Since 2014, the City's below market rate housing construction has been heavily skewed towards above-moderate income units, which have far outnumbered production of low and very-low income units. City of Santa Ana, Request for Council Action: General Plan Housing Element Annual Progress Report (March 17, 2020), attached as Exhibit E, at 3. The City's estimated Regional Housing Needs Assessment allocation for the 2021-2029 planning period is 3,086 housing units, including 360 low- income and 583 very-low-income units. DPEIR at 5-13-13; Southern California Association of Governments, Precertified Local Housing Data for the City of Santa Ana (August 2020), attached as Exhibit F, at 18. The DPEIR acknowledges that the Update "would directly induce substantial unplanned population growth" as well as employment growth, a significant impact which would further increase housing demand. DPEIR at 5.13-12 to 5.13-14 (Impact 5.13-1). The Willowick Community Park Proposal would help to address the City's affordable housing shortage, as it calls for 12 acres of the 1 Several census tracts adjacent to or near the Willowick site are designated as disadvantaged communities that experience a high pollution burden, including high concentrations of PM 2.5 and high occurrences of asthma and cardiovascular diseases. See CalEnviroScreen 3.0, https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-30.