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<br /> <br /> <br /> September 15, 2021 <br />Via Email <br /> <br />City of Santa Ana Planning Commission <br />20 Civic Center Plaza <br />Santa Ana, CA 92701 <br />c/o Commission Secretary Sarah Bernal <br />SBernal@santa-ana.org. <br /> <br />Re: Santa Ana General Plan Update Open Space Element <br /> <br />Dear Commissioners: <br />Rise Up Willowick appreciates the opportunity to comment on the City of Santa Ana’s <br />August 2021 draft General Plan Update (“the Update”). A memo to the Planning Commission on <br />the Update’s Open Space Element is attached as Exhibit A.1 We previously submitted comments <br />on an earlier draft of the Update in an October 6, 2020 letter to City planning staff, attached as <br />Exhibit B, and a November 9, 2020 letter to the Planning Commission, attached as Exhibit C. <br />Those earlier comments remain relevant to the draft Update and are hereby incorporated by <br />reference. <br />The policies and implementation actions in the Update’s Open Space Element seek to <br />avoid loss of parkland and create new public parkland, prioritizing currently underserved areas <br />and requiring private developments to create public open space. We commend the City for <br />revising these measures in response to public comments received on the previous draft Update. <br />However, the Open Space Element still falls short in several respects. <br />Most importantly, the City’s standard of two acres of parks per 1,000 residents is not <br />sufficient to meet the needs of City residents and is much less than the ratio of parkland to <br />residents in other comparable jurisdictions. The City should increase its park standard from two <br />to three acres of parkland per 1,000 residents. The City does not meet its current, low standard, <br />and under the Update the total “parkland deficiency” is projected to increase further, from 118.14 <br />acres to 299.48 acres at build-out unless the City develops new parks. RDPEIR at 5.15-28. In <br /> <br />1 These comments do not discuss the adequacy of the Update’s accompanying Recirculated Draft <br />Program Environmental Impact Report (“RDPEIR”) under the California Environmental Quality <br />Act, which is addressed in a separate letter to City planning staff submitted on behalf of Rise Up <br />Willowick by Shute, Mihaly & Weinberger LLP. <br />10/11/2021 <br />Planning Commission 1 –1