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Mr. Jerry Guevara The Bowery Project DEIR February 5, 2020 Page 2 2. The City of Santa Ana Municipal Code will require the project to pay park acquisition and development fees or dedicate land for park and recreational purposes. According to the DEIR, approximately 174,555 square feet of open space is proposed. However, this area includes private open space and perimeter open space and is not equivalent to park land provided. In any event, the project should be required to provide land for park and recreational purposes to meet the City of Santa Ana's minimum standard of "two (2) acres of property devoted to parks and recreational purposes for each thousand (1,000) persons residing within the City of Santa Ana." If on -site parkland is not required for the proposed project, residents of the project may be unable to find adequate parks in Santa Ana and may negatively impact parks and overburden parkland facilities in adjacent jurisdictions, including Tustin. These impacts must be mitigated. An analysis of the proposed project's compliance with the City of Santa Ana's park standards should focus on the potential to physically deteriorate existing and future recreational facilities in the City of Tustin, as the nearest existing and planned large scale recreational facilities are located in the City of Tustin. 3. According to Table 5.13-1 on page 5.13-2 of the DEIR, with one exception, the nearest City of Santa Ana parks are approximately two (2) to three (3) miles from the project site. As a comparison, the DEIR should analyze the distances from other similar existing City of Santa Ana residential neighborhoods to their nearest community parks. In addition, Table 5.13-2 on pages 5.13-3 and 5.13-4 of the DEIR, which lists City of Tustin and City of Irvine parks within the vicinity of the project site, should be modified to also include Ron Foell (Greenwood) Park. 4. It is stated on page 5.13-7 of the DEIR that based "on the existing amount of park and recreation facilities in the vicinity of the Project site, the recreation facilities that would be provided as part of the Project, and the number of residents at full capacity of the proposed Project, the Project is not anticipated to increase the use of existing parks and recreation facilities such that substantial physical deterioration of the facility would occur or be accelerated." However, this statement is not supported by any studies in the DEIR, which should analyze the actual anticipated usage of existing and proposed parks in the City of Tustin, especially those that will offer sports -oriented recreational facilities and playing fields that will not be provided as part of The Bowery Mixed Use Project. The proposed Veterans Sports Park at Tustin Legacy, for example, will be three times larger and about half the distance from the Project site than the closest park in Santa Ana and will offer new, state of art facilities that will be attractive to park users. The analysis in the DEIR should consider the quality, amenities, and attractiveness of nearby parks when estimating park usage. 5. The DEIR notes that any park fees collected for the Project would be expended for the acquisition, construction, and renovation of park and recreation facilities in Santa Ana. Therefore, it should also be noted in the DEIR that the collected park fees would not directly benefit any park facilities in Tustin. The statement in the DEIR that "by payment of the required park fees, the Project would provide funding to offset any Increased usage at other park and recreation facilities within Santa Ana. Overall, the proposed Project would not result in substantial physical deterioration of park and recreation facilities, and impacts would be less than significant" is misleading because it only applies to parks in Santa Ana and should not be used to reach the conclusion regarding deterioration of parks in Tustin.