CORRESPONDENCE - 75C - Laserfiche WebLink

Home Browse Search

Honorable Members of the Santa Ana City Council The Bowery Project FEIR August 18, 2020 Page 2 1. Santa Ana is continuing to take a noncomprehensive approach to new development proposed along the Red Hill Avenue corridor. This project is the second significant mixed -use project to be considered recently in the area and prior to the completion of the Santa Ana General Plan Update, which is currently underway. Santa Ana has routinely adopted site -specific General Plan Amendments to accommodate higher density development in recent years throughout the City, prior to completing its comprehensive General Plan Update. This is contrary to sound planning principles for many reasons. As just a few examples, it could lead to discordant development and prevents the public from understanding and evaluating Santa Ana's ultimate development aspirations for this area. The City of Tustin respectfully requests that the approval of this project be delayed until, at a minimum, a Master Plan can be developed and adopted for this area ensuring a comprehensive approach to development. 2. The proposed Santa Ana General Plan Update contemplates several areas of intensified land use. This project sits squarely within one of the focus areas for the City's General Plan Update. The cumulative impacts of this intensification need to be addressed comprehensively so that significant impacts can be properly identified and mitigated or avoided. Instead, the FEIR improperly defers the cumulative impacts analysis to sometime after this project is considered for approval. 3. Walkways and paseos, unusable perimeter landscape areas, private open space such as balconies, and other passive open space areas are being credited toward the project's minimum park land requirement. These areas are not equivalent to usable park land that usually accommodates sports fields and larger recreational spaces that are in high use and demand throughout Orange County. Walkways are not a substitute for, and will do little to alleviate impacts to, parks and athletic fields. Indeed, at least one (1) of the Santa Ana Planning Commissioners expressed a concern at the May 11, 2020 public hearing regarding the counting of walkways as park space or open space. Santa Ana has failed to provide a reasonable explanation or substantial evidence supporting this approach. As a result, the EIR's conclusions regarding the project's compliance with Santa Ana's park land requirement are unsupported. The issue of impacts to parks is more than just an environmental issue. This is a quality of life issue. Parks impacts should not be imposed on adjacent jurisdictions that have properly planned for growth and provided attractive recreational spaces for their residents. 4. The FEIR claims that impacts to Tustin parks are not significant and that sports league park usage fees fund maintenance and improvements. The project should be required to fund park maintenance and improvements in Tustin due to its proximity to Tustin parks. Alternatively, a park should be included on or near the project site, and/or the project density should be reduced. The Final FIR acknowledges that parks in Santa Ana and Tustin would generally be accessed by vehicle, and that the parks are beyond a 12-minute walking distance. This acknowledgement supports the need to require a new park facility on, or adjacent to, the project site. Indeed, the FEIR ignores potential impacts to the City of Tustin's passive open space park at the corner of Red Hill and Barranca Pkwy/Dyer Road. Due to its proximity to the proposed project (12- 1514217.1