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<br />Memo to City of Santa Ana Planning Commission <br />September 15, 2021 <br />Page 3 <br /> <br /> <br />Although the Open Space Element already includes a “no net loss of parkland” <br />implementation action (discussed below), the “no net loss” concept is so important and <br />fundamental that it should be articulated as a policy as well. Moreover, given the shortage <br />of both parks and open space in the City, this policy should apply to all open space, not <br />merely to parkland. The City already has a “parkland deficiency” of 118.14 acres, which <br />is expected to increase to 299.48 acres under the Update unless new parks are built. <br />RDPEIR at 5.15-28. Non-park open space provides an important supplemental <br />recreational resource, and can potentially be developed into parkland in the future. The <br />City cannot afford to lose any of its existing parkland or open space acreage. <br /> <br />3. Proposed Changes to the Update’s “No Net Loss” Implementation Action <br />The draft Open Space Element currently includes this provision: <br /> <br />Implementation Action [OS-]1.4: No-net-loss of parkland. Establish land use <br />provisions in the Municipal Code that prevent a net loss of public parkland in the <br />city. Require at least a 1:1 replacement if there is any loss of public parkland due <br />to public or private development. <br /> <br />City of Santa Ana Draft General Plan Update, Open Space Element, at 16. The City <br />proposes to enact the no-net-loss ordinance in 2022; the City’s Parks, Recreation and <br />Community Services Agency (PRCSA) would be responsible. <br /> <br /> We commend the City for including this “no net loss” implementation action in <br />the Update. However, as explained above, this provision should apply to all open space, <br />not only to parkland. The implementation action should specify that net loss of open <br />space will be avoided by prohibiting development that causes such a net loss. Moreover, <br />the provision should clarify that replacement parks and open space must be located <br />within 0.5 miles of the lost parks and open space, to ensure that the replacements serve <br />the same communities. Finally, the implementation action should require that <br />development of replacement parks and open space occur before the closure of the lost <br />parks or open space. This will ensure that there is not a lag or “gap” in time where <br />communities lose park or open space access if the replacement process is delayed. <br /> <br />We propose modifying Open Space Element Implementation Action OS-1.4 to <br />read as follows: <br /> <br />Implementation Action OS-1.4: No Net Loss of parkland Open Space. Establish <br />land use provisions in the Municipal Code that prevent prohibit development that <br />causes a net loss of public parkland Open Space in the city, including City parks as <br />well as other public and private land designated as Open Space under the General <br />Plan or the zoning code, but excluding any acreage of a golf course that is <br />10/11/2021 <br />Planning Commission 1 –7