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Verny Carvajal <br />October 6, 2020 <br />Page 8 <br />Similarly, he Update proposes a new "Industrial/Flex" land use designation in these <br />areas, which will promote "large-scale office industrial flex spaces, multi -level corporate <br />offices, and research and development uses." DPEIR at 3-18. The DPEIR must consider <br />the potential impacts of these newly -designated industrial areas on existing residents in <br />nearby housing. <br />IV. Conclusion <br />As currently proposed, the Update does not provide for sufficient open space or <br />affordable housing, and would undermine the City's Housing Opportunity Ordinance. As <br />set forth above, Rise Up Willowick urges the City to (1) continue to designate the <br />Willowick site as open space until and unless there is a proposal for developing part of it <br />with affordable housing, (2) provide for more affordable housing in order to avoid <br />undermining the HOO and causing an internal inconsistency within the General Plan, and <br />(3) revise the DPEIR to fully analyze the Update's impacts on displacement and <br />environmental justice. Rise Up Willowick respectfully requests that the City revise the <br />Update to address these issues, revise the DPEIR, and recirculate both for public <br />comment. <br />Very truly yours, <br />SHUTE, MIHALY & WEINBERGER LLP <br />Gabriel M.B. Ross <br />List of Exhibits: <br />Exhibit A: Trust for Public Land, Coastal Conservancy, and Clifford Beers Housing, <br />Willowick Community Park Proposal (August 2020) <br />Exhibit B: David J. Nowak and Gordon M. Heisler, National Recreation and Parks <br />Association, Air Quality Effects of Urban Trees and Parks (2010) <br />